Ministry of Foreign Affairs & Trade | 195 Lambton Quay, Private Bag 18 901, Wellington 5045, New Zealand
Ph +64 4 439 8000, | Email:info at mfat.govt.nz
Protocol amending the Agreement between New Zealand and the Federal Republic of Germany for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Certain Other Taxes
Treaty Type:
Bilateral/Plurilateral
Common Name:
Germany DTA
Responsible Department:
Inland Revenue
Administering Department:
Inland Revenue
Treaty Summary:
The aim of the negotiations is to agree a new Protocol to update the existing Double Tax Agreement (DTA) with Germany, which was signed in 1978. The primary purpose of the Protocol is to update the DTA with provisions to prevent base erosion and profit shifting (BEPS), as required or recommended by the OECD/G20 Inclusive Framework on BEPS.
NZ Adherence Status:
In Progress
Negotiation Status:
A first round of negotiations was held in October 2021 via video conferencing. A second round of negotiations was held in Berlin in Septermber 2024. A third round of negotiations was held in January 2025 via video conferencing.
Organisation:
Is Signed By NZ:
No
Signature Date:
Ratified or Signed:
No
Requires Ratification:
No
NZ Territorial Applications:
None
Information about required Legislation:
An Order in Council, made under section BH 1 of the Income Tax Act 2007, will be required to give effect to the new Protocol under New Zealand law.
Impacts on Maori:
No specific impact on Māori interests.
Impacts on Stakeholders:
The Protocol will update the DTA with measures to prevent tax planning strategies used by multinationals to avoid paying tax. Stakeholders currently using such strategies may therefore be required to restructure or pay more tax.
Link To Legislation:
Treaty Text Link:
Contact Information:
If you would like more information about this Treaty please contact us using our contact form.