(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 25, 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.
(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 this Agreement. Any agreement reached shall be implement-
ed notwithstanding any time limits in the domestic law of the
Contracting States.
(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 this
Agreement. They may also consult together for the elimination of
double taxation in cases not provided for in this Agreement.
(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 pre-
ceding paragraphs.
Citation to select or copy
Germany / Philippines; BGBl. 2014 II S. 822; edition de-philippines-2014-base | BGBl. 2014 II S. 822 | Signed: 2013-09-09 | Gazette publication: 2014-10-31; article 26; English; unreviewed source text, current applicability unverified; /editions/de-philippines-2014-base/en/articles/article-26/
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.
de-philippines-2014-base | BGBl. 2014 II S. 822 | Signed: 2013-09-09 | Gazette publication: 2014-10-31
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2014-10-31
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2013-09-09
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 2013 agreement replaces the 1983-07-22 agreement; retained official-article audit reports predecessor cessation 2015-12-17. Article32 transitional tax rules are retained, not simplified into one universal date. The accompanying protocol is separate. Later amendments, MLI and present applicability 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.
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-philippines-2014-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2013-09-09; consent law 2014-10-27; Gazette publication 2014-10-31; treaty entry into force 2015-12-18 (retained official-article audit evidence); general tax application from 2016-01-01 (BMF 2026 roster, not every tax-specific transition). Consent-law commencement 2014-11-01 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.