Germany and South Korea · Treaty signed
Germany and South Korea sign tax-treaty anti-abuse protocol
On 26 October 2026, South Korea and Germany signed a protocol amending their income-and-capital tax treaty, with the Korean Government highlighting stronger safeguards against tax avoidance and treaty abuse.
- Official document:
- Protocol amending the Korea–Germany agreement for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital; signature announcement of 30 October 2026
- Development date:
- 2026-10-26
The Korean Government announced the signature on 30 October. Foreign Minister Cho Hyun and German Ambassador Georg Wilfried Schmidt signed in Seoul. The official release identifies the instrument as an amending protocol to the bilateral agreement for avoiding double taxation and preventing fiscal evasion with respect to taxes on income and capital.[1]
The announcement places the amendment within OECD and G20 efforts to counter base erosion and profit shifting and offshore tax evasion. It says the protocol strengthens cooperation against tax avoidance, including by preventing treaty benefits for transactions undertaken for tax-avoidance purposes. It does not reproduce the operative anti-abuse wording or identify an article-by-article test.[1]
Signature does not establish current entitlement
For multinational groups using the Germany–Korea treaty, this is a development to monitor rather than a basis for changing withholding rates or claiming relief. The opened announcement does not supply the signed protocol text, ratification status, entry-into-force date or tax-specific application provisions. No numerical rate change, new filing deadline or immediately operative restriction is established by this report. Those questions require the protocol and subsequent competent-authority notices before a group changes an existing position.[1]
Official sources
- [1] Korea–Germany double-taxation agreement amending protocol signature — official release
Republic of Korea Ministry of Foreign Affairs and Ministry of Finance and Economy · Document date: 2026-10-30
Complete two-page Korean PDF downloaded from the official policy briefing attachment and read with pdftotext. Page 1 identifies signature on 26 October in Seoul, signatories, treaty title, BEPS cooperation and anti-abuse purpose; page 2 ministry attribution. Web reader could not parse download; direct ordinary HTTP retrieval succeeded. No signed protocol text or commencement provisions supplied.