RETAINED RECORD: NON-OPERATIVE / NOT IN FORCE · NICHT IN KRAFT · 2008 source edition
Source edition / Quellenfassung

Interface language: English. Document language: English (EN).

de-south-africa-2008-not-in-force · EN

Article 26 Limitation of Benefits

2024 protocol not incorporatedUnreviewed · applicability unverified

All 30 articles

Source paragraph 1

(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).

Source paragraph 2

(2) If the above provisions result in double taxation, the competent authorities shall consult each other pursuant to paragraph 3 of Article 24 in order to eliminate double taxation.

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