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1Article 1 Persons Covered2Article 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 Income from Employment15Article 15 Directors’ Fees16Article 16 Artistes and Sportsmen17Article 17 Pensions, Annuities and Similar Payments18Article 18 Government Service19Article 19 Professors and Teachers20Article 20 Students and Business Apprentices21Article 21 Other Income22Article 22 Special Provisions23Article 23 Elimination of Double Taxation24Article 24 Non-discrimination25Article 25 Mutual Agreement Procedure26Article 26 Exchange of Information27Article 27 Assistance in the Collection of Taxes28Article 28 Procedural Rules for Taxation at Source29Article 29 Application of the Agreement in Special Cases30Article 30 Members of Diplomatic Missions and Consular Posts31Article 31 Protocol32Article 32 Entry into Force33Article 33 Termination

33 articles · English

Source & edition
Country pairs / Germany / Mauritius

Germany / Mauritius · 2012 source edition

Article 25 Mutual Agreement Procedure

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 15
(1) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in tax- ation not in accordance with the provisions of this Agreement.
§ PDF page 15
(2) The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implement- ed notwithstanding any time limits in the domestic law of the Contracting States.
§ PDF page 15
(3) The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement.
§ PDF page 15
(4) The competent authorities of the Contracting States may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs.
Citation to select or copy

Germany / Mauritius; BGBl. 2012 II S. 1050; edition de-mauritius-2012-base | BGBl. 2012 II S. 1050 | Signed: 2011-10-07 | Gazette publication: 2012-10-09; article 25; English; unreviewed source text, current applicability unverified; /editions/de-mauritius-2012-base/en/articles/article-25/

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. 2012 II S. 1050

  • Original PDF Official source website ↗

    SHA-256 bd5b5aff9b41c4b21c0c62bc2e2b3ba2798236a1e1e886dec8f45ae3680426a4

Edition
de-mauritius-2012-base | BGBl. 2012 II S. 1050 | Signed: 2011-10-07 | Gazette publication: 2012-10-09
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2012-10-09
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2011-10-07
Edition notes and known limitations

Original source edition; not a verified current-law consolidation. BASE EDITION WITH KNOWN LATER AMENDMENT OMITTED. The 2021-10-29 amendment is not incorporated; its exact entry date remains unresolved. No current-law clearance. 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 integral protocol signed 7 October 2011 is retained separately. A LATER AMENDING PROTOCOL signed 29 October 2021 is NOT included or consolidated here. The 2026 roster records general application from 1 January 2023 and cites the entry notice BGBl. 2023 II No.50; the official article still displays ./. for protocol entry into force. Exact amendment entry date and tax-specific effect remain UNRESOLVED pending examination of that notice. Do not treat this base edition as current consolidated law. MLI and any other later changes are not exhaustively verified. 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. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2021-10-29; general application from: 2023-01-01; limit: Exact tax-specific application remains for protocol review.

The signing clause identifies German and English as equally authentic; both are supplied as separate machine transcriptions. No additional authentic language is identified in that 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-mauritius-2012-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2011-10-07; consent law 2012-10-02; Gazette publication 2012-10-09; treaty entry into force 2012-12-07 (retained official-article audit evidence); general tax application from 2013-01-01 (BMF 2026 roster, not every tax-specific transition). Consent-law commencement 2012-10-10 is NOT treaty entry into force. 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.

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