The UK has published the Double Taxation Relief (Federal Republic of Germany) Order 2021, which was made on 26 May 2021 and provides for the ratification of the pending protocol to the 2010 income and capital tax treaty with Germany. The protocol, signed 12 January 2021, is the second to amend the treaty and provides for the implementation of the minimum BEPS standards and certain other changes.

The protocol will enter into force once the ratification instruments are exchanged. It will apply in Germany from 1 January of the year following its entry into force. It will apply in the UK in respect of withholding taxes from 1 January in the calendar year next following its entry into force, in respect of corporation tax from 6 April in the calendar year next following its entry into force, and in respect of income tax and capital gains tax from 1 April in the calendar year next following its entry into force.