(1) Notwithstanding the provisions of Articles 7 and 14‚ income derived by a resident of
a Contracting State as an entertainer‚ such as a theatre‚ motion picture‚ radio or television
artiste‚ or a musician‚ or as a sportsperson‚ from that person’s personal activities as such
exercised in the other Contracting State‚ may be taxed in that other State.
(2) Notwithstanding the provisions of Article 12‚ income derived by the persons
mentioned in paragraph 1 from their personal activities exercised in the other Contracting
State shall also include remuneration of any kind paid for the use of‚ or the right to use‚
the name‚ the picture or other personal rights of such persons as well as any consideration
for the recording and transmission of the activities mentioned in paragraph 1 by radio or
television.
(3) Where income mentioned in paragraphs 1 and 2 accrues not to the entertainer or
sportsperson but to another person‚ that income may‚ notwithstanding the provisions of
Articles 7 and 14‚ be taxed in the Contracting State in which the activities of the
entertainer or sportsperson are exercised.
(4) Paragraphs 1 and 3 shall not apply to income derived by a resident of a Contracting
State from activities exercised in the other Contracting State if the visit to that other State
is supported wholly or mainly by public funds of the first-mentioned State‚ a Land‚ a
political subdivision or a local authority thereof‚ or takes place under a cultural agreement
or arrangement between the Governments of the Contracting States. In such case‚ the
income shall be taxable only in the Contracting State of which the entertainer or
sportsperson is a resident.
Citation to select or copy
Germany / South Africa; Germany / South Africa, 2008 convention source publication; edition de-south-africa-2008-not-in-force; article 16; English; unreviewed source text, current applicability unverified; /editions/de-south-africa-2008-not-in-force/en/articles/article-16/
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
Germany / South Africa, 2008 convention source publication
BMF currently lists the agreement dated 9 September 2008 as “noch nicht in Kraft getreten”. This is the 2008 source publication, not the 1973 agreement. BMF separately lists the amending protocol dated 6 March 2024 as not yet in force; that separate protocol is not incorporated here. The integral protocol supplied with the 2008 source remains part of this edition. Entry/termination provisions in the treaty body are conditions, not evidence that this agreement entered into force. The source reader may remain searchable with this label.
BMF instrument date, not entry/effect
2008-09-09
separate amending-protocol date, not entry/effect
2024-03-06
No entry/effect date established; BMF lists both not yet in force at retrieval
No universal date asserted
Retained status evidence and exact quotes
German Federal Ministry of Finance (BMF) · 2008 Germany–South Africa agreement only; not 1973 instrument
Abkommen vom 9. September 2008Inkrafttreten:noch nicht in Kraft getreten
Publisher-reported status only. Currentness and human legal approval remain unverified.
Edition
de-south-africa-2008-not-in-force
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Edition notes and known limitations
Entry/termination clauses are source wording, not proof of ratification or operation. References to the 1973 agreement inside the 2008 source remain verbatim, but no 1973/1974 body has been imported.
The separate 2024 protocol is not incorporated. Not part of any current-law count.
BMF currently lists the agreement dated 9 September 2008 as “noch nicht in Kraft getreten”. This is the 2008 source publication, not the 1973 agreement. BMF separately lists the amending protocol dated 6 March 2024 as not yet in force; that separate protocol is not incorporated here. The integral protocol supplied with the 2008 source remains part of this edition. Entry/termination provisions in the treaty body are conditions, not evidence that this agreement entered into force. The source reader may remain searchable with this label.