On 26 October 2026, officials from Germany and South Korea signed an amending protocol to the 2000 income and capital tax treaty between the two countries. The protocol is the first to amend the treaty and includes the following changes:
- The preamble is replaced in line with OECD BEPS standards;
- Paragraph 4 of Article 5 (Permanent Establishment) is replaced regarding the activities that are not deemed to constitute a permanent establishment; and
- Paragraph 2 of Article 27 (Application of the …