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

The amending protocol to the 2012 tax treaty between Germany and Luxembourg entered into force on 29 December 2023. The protocol, signed 6 July 2023, is the first to amend the treaty. Some of the main changes include the following:

• The preamble is replaced in line with BEPS standards;
• Article 1 (Persons Covered) is amended with the addition of a new paragraph 2, providing that for the purposes of the treaty, income derived by or through an entity or arrangement that is treated as wholly or p…