On 24 November 2023, the German Federal Council (upper house of parliament - Bundesrat) approved the law for the ratification of the pending protocol to the 2000 tax treaty with Austria. The protocol, signed 21 August 2023, is the second to amend the treaty and includes the following changes:

• The title and preamble are replaced in line with BEPS standards;
• Article 5 (Permanent Establishment) i…