Amending Protocol to Tax Treaty between Germany and Mexico has Entered into Force

The amending protocol to the 2008 income and capital tax treaty between Germany and Mexico entered into force on 6 August 2023. The protocol, signed 8 October 2021, is the first to amend the treaty and includes the following changes:

• The preamble is replaced in line with OECD BEPS standards;
• Article 5 (Permanent Establishment) is updated in relation to activities of a preparatory or auxiliary character that do not result in a PE;
• Article 10 (Dividends) is amended to introduce a minimum holdi…