EN · Physical source page 7

Original, non-operative source publication · NOT IN FORCE / NICHT IN KRAFT

Signed Berlin, 9 September 2008. Unreviewed machine transcription, not legal advice, current law or a complete current treaty chain. No human wording, alignment or publication approval.

The cached BMF article states “noch nicht in Kraft getreten” for both the 2008 agreement and the separate 6 March 2024 protocol. This is a retained observation, not fresh currentness proof. The 2024 protocol is NOT incorporated or acquired. Only the integral 2008 protocol is included.

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EN original PDF · Both source hashes and provenance · Complete 2008 source supplements

Complete native lines of physical PDF page 7. Page-number furniture is retained. Source coordinate order, not a facsimile or human-verified typography.

PDF 7 · en-pdf-007-line-001- 7 -
PDF 7 · en-pdf-007-line-002a) the individual shall be deemed to be a resident solely of the State in which a
PDF 7 · en-pdf-007-line-003permanent home is available to the individual; if a permanent home is available to
PDF 7 · en-pdf-007-line-004the individual in both States‚ the individual shall be deemed to be a resident solely
PDF 7 · en-pdf-007-line-005of the State with which the individual’s personal and economic relations are closer
PDF 7 · en-pdf-007-line-006(centre of vital interests);
PDF 7 · en-pdf-007-line-007b) if sole residence cannot be determined under the provisions of subparagraph (a)‚ the
PDF 7 · en-pdf-007-line-008individual shall be deemed to be a resident solely of the State in which the
PDF 7 · en-pdf-007-line-009individual has an habitual abode;
PDF 7 · en-pdf-007-line-010c) if the individual has an habitual abode in both States or in neither of them‚ the
PDF 7 · en-pdf-007-line-011individual shall be deemed to be a resident solely of the State of which the
PDF 7 · en-pdf-007-line-012individual is a national;
PDF 7 · en-pdf-007-line-013d) if the individual is a national of both States or of neither of them‚ the competent
PDF 7 · en-pdf-007-line-014authorities of the Contracting States shall settle the question by mutual agreement.
PDF 7 · en-pdf-007-line-015(3) Where by reason of the provisions of paragraph 1 a person other than an individual is
PDF 7 · en-pdf-007-line-016a resident of both Contracting States‚ then it shall be deemed to be a resident solely of the
PDF 7 · en-pdf-007-line-017State in which its place of effective management is situated.
PDF 7 · en-pdf-007-line-018Article 5
PDF 7 · en-pdf-007-line-019Permanent Establishment
PDF 7 · en-pdf-007-line-020(1) For the purposes of this Agreement‚ the term ”permanent establishment” means a
PDF 7 · en-pdf-007-line-021fixed place of business through which the business of an enterprise is wholly or partly
PDF 7 · en-pdf-007-line-022carried on.
PDF 7 · en-pdf-007-line-023(2) The term ”permanent establishment” includes especially: