The amending protocol to the 2012 tax treaty between Germany and the Netherlands enters into force on 31 December 2025. The protocol, signed 14 April 2025,is the third to amend the treaty and includes the following main changes:
- Article 3 (General Definitions) is amended with the addition of a definition of the term "undertaking for collective investment";
- Subparagraph a) of paragraph 2 of Article 10 ( Dividends) is replaced, providing a 5% withholding tax rate if the beneficial owner is a c…