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1Article 1 Personal Scope2Article 2 Taxes Covered3Article 3 General Definitions4Article 4 Resident5Article 5 Permanent Establishment6Article 6 Income from Immovable Property7Article 7 Business Profits8Article 8 Shipping and Air Transport9Article 9 Associated Enterprises10Article 10 Dividends11Article 11 Interest12Article 12 Royalties13Article 13 Capital Gains14Article 14 Independent Personal Services15Article 15 Dependent Personal Services16Article 16 Directors’ Fees17Article 17 Artistes and Sportsmen18Article 18 Pensions, Annuities and Similar Payments19Article 19 Government Service20Article 20 Visiting Professors, Teachers and Students21Article 21 Other Income22Article 22 Capital23Article 23 Avoidance of Double Taxation in the State of Residence24Article 24 Non-discrimination25Article 25 Mutual Agreement Procedure26Article 26 Exchange of Information27Article 27 Limitation of Benefits28Article 28 Members of Diplomatic Missions and Consular Posts29Article 29 Application of Protocol30Article 30 Registration of Agreement31Article 31 Entry into Force32Article 32 Termination

32 articles · English

Source & edition
Country pairs / Germany / Malta

Germany / Malta · 2001 source edition

Article 27 Limitation of Benefits

English · original source edition

Unreviewed · applicability unverified
Original & source
Deutsch contents

Choose a contents page: no source-verified article correspondence is available. Legal or translation equivalence has not been reviewed.

§ PDF page 17
1. This Agreement shall not be interpreted to mean that a) a Contracting State is prevented from applying its domestic legal provisions on the prevention of tax evasion or tax avoidance; b) the Federal Republic of Germany is prevented from levying taxes on amounts which are to be included in the items of income of a resident of the Federal Republic of Germany under the Fourth Part of the German Law on External Tax Relations (Aussensteuergesetz).
§ PDF page 17
2. The provisions of this Agreement shall not apply to com- panies or other persons enjoying a special fiscal treatment by virtue of the laws or the administrative practice of either one of the Contracting States. Neither shall they apply to income derived from such companies or other persons derived by a resident of the other Contracting State, nor to shares or other rights in such companies owned by such a resident.
Citation to select or copy

Germany / Malta; BGBl. 2001 II S. 1297; edition de-malta-2001-base | BGBl. 2001 II S. 1297 | Signed: 2001-03-08 | Gazette publication: 2001-12-17; article 27; English; unreviewed source text, current applicability unverified; /editions/de-malta-2001-base/en/articles/article-27/

Disclaimers

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.

Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.

Noindex is not access control. This is a research preview, not a statement of authoritative or current law.

Source & edition

BGBl. 2001 II S. 1297

  • Original PDF Official source website ↗

    SHA-256 e731130706a5be3e27f9ae7af1389f29dec54d4725ad0751cef4e7104a7c5887

Edition
de-malta-2001-base | BGBl. 2001 II S. 1297 | Signed: 2001-03-08 | Gazette publication: 2001-12-17
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2001-12-17
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2001-03-08
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. Original 2001 edition is not a consolidated 2026 text: 2010 amendment and operative MLI effects are omitted. Cached article prints BGBl. 2001 II S. 320 for entry notice, but roster prints 2002 II S. 320 and linked notice has 2002 date. Preserve discrepancy; use roster citation with explicit correction provenance.

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: Original 2001 edition is not a consolidated 2026 text: 2010 amendment and operative MLI effects are omitted. Cached article prints BGBl. 2001 II S. 320 for entry notice, but roster prints 2002 II S. 320 and linked notice has 2002 date. Preserve discrepancy; use roster citation with explicit correction provenance. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2010-06-17; citation: BGBl. 2011 II S. 275; entry notice S. 640; entry into force: 2011-05-19; application caveat: I.1 prints 01.01.2002 for protocol application. Preserve that broad table statement; do not infer that every amendment is retroactive without protocol review. / BEPS-MLI; citation: BGBl. 2024 I Nr. 205; BGBl. 2025 II Nr. 5; general application: 2025-01-01; part VI general application: 2024-11-01

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-malta-2001-base/. PDF page links identify pages, not verified paragraph correspondence.

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