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The UK ratified the protocol to its double tax treaty (DTT) with Germany on 26 May 2021 (SI2021/634), giving UK domestic effect to the protocol which was signed by the two countries on 12 January 2021. Germany has also recently incorporated the protocol into its domestic legislation (Fed Gazette 259/21 of 23 July 2021).

Exchange of instruments of ratification is therefore expected shortly. The protocol will come into force on the day that exchange takes place.

The protocol is unlikely to have significant impact in the UK or Germany, but may create additional challenge on the PE status of UK groups with large operations in Germany where selling is not being done via a local German company.