(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, in particular 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 en-
terprise 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 reductions for taxa-
tion purposes on account of civil status or family responsibilities
which it grants to its own residents.
(4) Except where the provisions of paragraph 1 of Article 9,
paragraph 4 of Article 11, or paragraph 5 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.
Similarly, any debts of an enterprise of a Contracting State to a
resident of the other Contracting State shall, for the purpose of
determining 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
burdensome than the taxation and connected requirements to
which other similar enterprises of the first-mentioned State are
or may be subjected.
de-ireland-2011-base | BGBl. 2011 II S. 1042 (consent law); S. 1043–1067 (agreement, protocol and joint declaration) | signed 2011-03-30 | published 2011-11-07 | Signed: 2011-03-30 | Gazette publication: 2011-11-07
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2011-11-07
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2011-03-30
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Signed at Dublin 2011-03-30; consent law 2011-11-01; gazette publication 2011-11-07. Treaty entry 2012-11-28, not application; entry notice dated 2013-02-11, published 2013-03-20. Article 32(2) general application from 2013-01-01 is qualified by tax-specific rules and transitional paragraphs 32(3)–(5). Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified.
Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Source-triage warnings: Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified. Known related/later instruments NOT included in this source (agent triage, not exhaustive): later-amending-protocol; signature date: 2014-12-03; limit: Cached BMF article; amendment body not incorporated; no current-law claim / later-amending-protocol; signature date: 2021-01-19; limit: Cached BMF article; amendment body not incorporated; no current-law claim / later-official-2025-consolidation; date: 2025-04-10; limit: Separate central record and held W intake preserved; no reclassification or body mixing
Unreviewed machine transcription. Original 2011 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, indexing, deployment or publication approval. Noindex preview only; noindex is not access control. Published treaty languages: German and English. Original closing on physical page 21 declares both texts equally authoritative. Both bodies come exclusively from the original 2011 PDF. No third language, translation or cross-language paragraph alignment is inferred. English interface; legal source containers carry their own language. Source-proved reversible blank-glyph CMap correction only; no OCR, translation, wording/spacing/hyphen repair. Native spans and coordinate gaps retained; all26 original/derivative renders identical. Law, preamble, execution, signatures, integral protocol and joint declaration: /review/de-ireland-2011-base/. Source links indicate pages, not independently approved paragraph alignment.