A Protocol amending the existing Convention between the Kingdom of the Netherlands and the Federal Republic of Germany for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income as concluded in Berlin on April 12, 2012 as amended by the Protocol of March of 24, 2021 has been published in the Dutch Treaty Gazette of May 1, 2025. The text of the Protocol was published in both the Dutch and the German language.
The Protocol amends the Convention as follows:
- Article 3, Paragraph 1 (‘Definitions’) is amended;
- Paragraphs 2 and 3 of Article 10 (‘Dividends’) is amended;
- A new Paragraph 1a is included in Article 14 (‘Independent personal services’);
- Article 14, Paragraph 2 (‘Independent personal services’) is amended;
- Article 18, Paragraph 1 (‘Government functions’) is replaced by a new Paragraph; and
- Paragraphs 1 and 2 of Article 22 (‘Exemption method’) is amended.
The Protocol furthermore amends the existing Protocol to the Convention.
Both the Dutch and the German version of the amending Protocol as published in the Dutch Treaty Gazette can be found here.
Both the consolidated Dutch and the consolidated German text of the existing Convention between the Kingdom of the Netherlands and the Federal Republic of Germany for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income as concluded in Berlin on April 12, 2012 as amended by the Protocol of March of 24, 2021 as published in the Dutch Treaty Gazette can be found here.
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