(January 21, 2015)

On its webpage dedicated to Tax Treaties the Irish Tax and Customs has published a Protocol amending the Agreement between Ireland and the Federal Republic of Germany for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital done at Dublin on 30 March 2011. The Protocol was signed on December 3, 2014.

Although the Protocol has been signed, it has not yet entered into force. The Protocol will enter into force after both countries have finalized their respective ratification processes.

The protocol a.o. arranges that Article 7 “Business profits” will be deleted and replaced by a new Article 7 “Business profits”. The new Article 7 a.o. contains an appropriate adjustment/mutual agreement clause. 

Furthermore the term boat is added in several places to the text of paragraph 3 of Article 8 “Shipping, inland waterways transport and air transport”

For further information click here to be forwarded to the text of the Protocol as published on the website of the Irish Tax and Customs. Click here for the text of the Agreement between Ireland and the Federal Republic of Germany for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital done at Dublin on March 30, 2011 as published on the website of the Irish Tax and Customs. Click here for the text of the Protocol from May 25, 2010 as published on the website of the Irish Tax and Customs.

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