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Germany: Protocols to tax treaties with Netherlands, Switzerland enter into force

Applies from January 1, 2026

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January 29, 2026

The Germany–Netherlands amending protocol to the 2012 income tax treaty, as previously amended, entered into force on December 31, 2025. The protocol generally applies from January 1, 2026, for withholding and other taxes.

The amending protocol to the 1971 Germany–Switzerland income and capital tax treaty entered into force on November 27, 2025. The protocol—signed on August 21, 2023—applies from January 1, 2026, for most provisions and introduces BEPS-compliant measures, including an anti-abuse clause and updates to mutual agreement procedures.


For more information, contact a KPMG tax professional in Germany:

Julian Fey | jfey@kpmg.com

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