On 12 June 2013, the Netherlands and United Kingdom signed an amending protocol to the Netherlands - United Kingdom Income Tax Treaty (2008), in London. The most important details of the protocol are summarized below. (a) Business profits Article I of the protocol provides for the implementation of new article 7 of the OECD Model. Article 7(1) provides that profits of an enterprise of a contracting state will be taxable only in residence state unless the enterprise carries on business in the other contracting state through a permanent. In that case, the profits that are attributable to the permanent establishment...