Germany and Korea (Rep.) signed an amending protocol to their 2000 income and capital tax treaty on 26 October 2026, aligning the preamble with OECD BEPS standards, revising Article 5 on permanent establishment and introducing a principal purpose test.
Germany and Korea ( Rep.) signed an amending protocol to the 2000 income and capital tax treaty between the two countries on 26 October 2026.
The protocol updates the treaty preamble in line with OECD BEPS standards and revises Article 5 (Permanent Establishment) to clarify activities that do not constitute a permanent establishment.
It also replaces Paragraph 2 of Article 27 (Application of the Agreement in Special Cases) with a principal purpose test, introducing a broader treaty benefit restriction in place of the previous Article-specific limitations on benefits.
The protocol will take effect 30 days after the exchange of ratification instruments, with its provisions applying from 1 January of the subsequent year.
