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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, Inland Waterways Transport 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 Professors 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 Procedural Rules for Taxation at Source28Article 28 Application of the Convention in Special Cases29Article 29 Members of Diplomatic Missions and Consular Posts30Article 30 Protocol31Article 31 Entry into Force32Article 32 Termination

32 articles · English

Source & edition
Country pairs / Germany / Romania

Germany / Romania · 2003 source edition

Article 22 Capital

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 14
(1) Capital represented by immovable property, owned by a resident of a Contracting State and situated in the other Con- tracting State may be taxed in that other State.
§ PDF page 14
(2) Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services may be taxed in that other State.
§ PDF page 14
(3) Capital represented by ships and aircraft operated in inter- national traffic, and by boats engaged in inland waterways trans- port, and by movable property pertaining to the operation of such ships and aircraft and boats, shall be taxable only in the Con- tracting State in which the place of effective management of the enterprise is situated.
§ PDF page 14
(4) All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
Citation to select or copy

Germany / Romania; BGBl. 2003 II S. 1594; edition de-romania-2003-base | BGBl. 2003 II S. 1594 | signed 2001-07-04 | published 2003-11-14 | Signed: 2001-07-04 | Gazette publication: 2003-11-14; article 22; English; unreviewed source text, current applicability unverified; /editions/de-romania-2003-base/en/articles/article-22/

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. 2003 II S. 1594

  • Original PDF Official source website ↗

    SHA-256 aa227eb9367b81d0bd6e85ee8dcb0c0b198a04ea9346fb3d268ca6ee537f0906

Edition
de-romania-2003-base | BGBl. 2003 II S. 1594 | signed 2001-07-04 | published 2003-11-14 | Signed: 2001-07-04 | Gazette publication: 2003-11-14
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2003-11-14
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2001-07-04
Edition notes and known limitations

Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2001-07-04; consent law 2003-11-12; gazette publication 2003-11-14. Edition ID year is not a signature date. Treaty entry into force: 2003-12-17. Roster general application: 2004-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 17. Dezember 2003. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. 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.

Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Rumänien R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. 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.

German and English are separate complete physical source regions. The closing also names Romanian, NOT printed as a separate language version in this retained original; no Romanian asset or translation. English precedence clause is retained. 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-romania-2003-base/. PDF page links identify pages, not verified paragraph correspondence. Native Type1 diagnostic recovery: all used font codes independently mapped and glyphs loaded; only overlong Copyright metadata lines remain as retained Poppler warnings. No text repair or warning suppression. Full machine evidence and full physical pages: /geometry/de-romania-2003-base/.

Retained metadata & integrity record

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