Luxembourg Approves Pending Protocol to Tax Treaty with Germany

On 28 July 2023, Luxembourg's Government Council approved the ratification of the pending protocol to the 2012 income and capital tax treaty with Germany. 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 arr…