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Amendment of the German-Irish income tax treaty

Sven-Eric Bärsch 10 Feb 2021

On 19 January 2021, lawmakers signed amendments to the protocol in the German-Irish income tax treaty.

On 19 January 2021, lawmakers signed amendments to the protocol in the German-Irish income tax treaty.

The key points of the amendments are:

• the introduction of a new provision in targeting treaty abuse;
• the revision of the permanent establishment standard by introducing the anti-fragmentation rule; and
• the introduction of a 365-day holding period for the reduction of withholding tax on dividends.

Discover more: Amendment of the German-Irish income tax treaty

Article tags

Germany | Income Tax | Ireland