The new income tax treaty between Germany and the Netherlands was signed 12 April 2012. Once in force and effective it will replace the 1959 income and capital tax treaty between the two countries, which currently applies. Taxes Covered The treaty covers German income tax, corporation tax and trade tax. It covers Dutch income tax, wages tax, company tax and dividend tax. Offshore PE The treaty includes the provision that a permanent establishment will be deemed constituted if an enterprise of one Contracting State carries on offshore activities in the territorial sea of the other State for a period or...