(1) Nationals of a Contracting State shall not be subjected in
the other Contracting State to any taxation or any requirement
connected therewith which is other or more burdensome than
the taxation and connected requirements to which nationals of
that other State in the same circumstances, especially with
respect to residence, are or may be subjected. This provision
shall, notwithstanding the provisions of Article 1, also apply to
persons who are not residents of one or both of the Contracting
States.
(2) Stateless persons who are residents of a Contracting State
shall not be subjected in either Contracting State to any taxation
or any requirement connected therewith, which is other or more
burdensome than the taxation and connected requirements to
which nationals of the State concerned in the same circum-
stances are or may be subjected.
(3) The taxation on a permanent establishment which an
enterprise of a Contracting State has in the other Contracting
State shall not be less favourably levied in that other State than
the taxation levied on enterprises of that other State carrying on
the same activities. This provision shall not be construed as
obliging a Contracting State to grant to residents of the other
Contracting State any personal allowances, reliefs and reduc-
tions for taxation purposes on account of civil status or family
responsibilities which it grants only to its own residents.
(4) Except where the provisions of paragraph 1 of Article 9,
paragraph 7 of Article 11, or paragraph 6 of Article 12, apply,
interest, royalties and other disbursements paid by an enterprise
of a Contracting State to a resident of the other Contracting State
shall, for the purpose of determining the taxable profits of such
enterprise, be deductible under the same conditions as if they
had been paid to a resident of the first-mentioned State. Similar-
ly, any debts of an enterprise of a Contracting State to a resident
of the other Contracting State shall, for the purpose of determin-
ing the taxable capital of such enterprise, be deductible under
the same conditions as if they had been contracted to a resident
of the first-mentioned State.
(5) Enterprises of a Contracting State, the capital of which is
wholly or partly owned or controlled, directly or indirectly, by one
or more residents of the other Contracting State, shall not be
subjected in the first-mentioned State to any taxation or any
requirement connected therewith which is other or more burden-
some than the taxation and connected requirements to which
other similar enterprises of the first-mentioned State are or may
be subjected.
de-albania-2011-base | BGBl. 2011 II S. 1186 | Signed: 2010-04-06 | Gazette publication: 2011-12-08
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2011-12-08
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2010-04-06
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
German and English are supplied. The signing clause additionally identifies Albanian as authentic; Albanian is NOT present in this reader. The English text prevails in divergent interpretation of German and Albanian according to the closing clause. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-albania-2011-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2010-04-06; consent law 2011-12-05; Gazette publication 2011-12-08; treaty entry into force 2011-12-23 (retained official-article audit evidence); general application from 2012-01-01 (roster, not universal tax-specific start). Encoding-recovery method: only the source font code00 /space Unicode mapping U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyph, 278-unit advance, unchanged page content streams and 23/23 identical source/derivative page renders for this edition evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No model-generated treaty wording and no OCR.