The last quarter of 2025 and the beginning of 2026 saw several significant developments in bilateral double taxation treaties (DTTs). These developments include amendments through protocols, the entry into force of new treaties, and the modernization of existing agreements to reflect post-BEPS standards and evolving cross-border employment patterns. The following sections outline the most relevant treaties and emphasize the principal changes introduced.

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Netherlands – Germany: Protocol Amending the 2012 Double Tax Treaty

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A protocol signed on 14 April 2025 amended the 2012 double taxation treaty between the Netherlands and Germany. The amendment entered into force on 31 December 2025 and applies from 1 January 2026. The principal change introduced by the protocol addresses the tax treatment of cross-border telework. Traditionally, employment income under tax treaties is taxed in the jurisdiction where the work is physically performed.

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