(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 require-
ments to which nationals of the State concerned in the same
circumstances 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 which it grants only to its own resi-
dents.
(4) Except where the provisions of paragraph 1 of Article 9,
paragraph 8 of Article 11 or paragraph 7 of Article 12 apply,
interest, royalties, services fees 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 tax-
able profits of such enterprise, be deductible under the same
conditions as if they had been paid to a resident of the first-
mentioned State. Similarly, any debts of an enterprise of a Con-
tracting State to a resident of the other Contracting State shall,
for the purpose of determining the taxable capital of such enter-
prise, 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 bur-
densome than the taxation and connected requirements to
which other similar enterprises of the first-mentioned State are
or may be subjected.
de-ghana-2006-base | BGBl. 2006 II S. 1018 | Signed: 2004-08-12 | Gazette publication: 2006-12-07
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2006-12-07
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2004-08-12
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. No later amendment identified in roster I.1 or cached/fetched BMF article. The October1 HTML section was checked and matches the cache; this is not exhaustive currentness certification. Ghana is not listed in roster I.2 as of2026-01-01. A country-page omission does not prove absence of all later MLI/legal developments.
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: No later amendment identified in roster I.1 or cached/fetched BMF article. The October1 HTML section was checked and matches the cache; this is not exhaustive currentness certification. Ghana is not listed in roster I.2 as of2026-01-01. A country-page omission does not prove absence of all later MLI/legal developments.
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-ghana-2006-base/. PDF page links identify pages, not verified paragraph correspondence.