EN · Physical source page 10

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.

German and English are equally authentic according to the source closing clauses. This reader makes no approved cross-language alignment claim. Entry/termination language below is source wording, not evidence of operation.

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

Complete native lines of physical PDF page 10. Page-number furniture is retained. Source coordinate order, not a facsimile or human-verified typography.

PDF 10 · en-pdf-010-line-001- 10 -
PDF 10 · en-pdf-010-line-002(7) The fact that a company which is a resident of a Contracting State controls or is
PDF 10 · en-pdf-010-line-003controlled by a company which is a resident of the other Contracting State‚ or which
PDF 10 · en-pdf-010-line-004carries on business in that other State (whether through a permanent establishment or
PDF 10 · en-pdf-010-line-005otherwise)‚ shall not of itself constitute either company a permanent establishment of the
PDF 10 · en-pdf-010-line-006other.
PDF 10 · en-pdf-010-line-007Article 6
PDF 10 · en-pdf-010-line-008Income from Immovable Property
PDF 10 · en-pdf-010-line-009(1) Income derived by a resident of a Contracting State from immovable property
PDF 10 · en-pdf-010-line-010(including income from agriculture or forestry) situated in the other Contracting State
PDF 10 · en-pdf-010-line-011may be taxed in that other State.
PDF 10 · en-pdf-010-line-012(2) The term ”immovable property” shall have the meaning which it has under the law of
PDF 10 · en-pdf-010-line-013the Contracting State in which the property in question is situated. The term shall in any
PDF 10 · en-pdf-010-line-014case include property accessory to immovable property‚ livestock and equipment used in
PDF 10 · en-pdf-010-line-015agriculture and forestry‚ rights to which the provisions of general law respecting landed
PDF 10 · en-pdf-010-line-016property apply‚ usufruct of immovable property and rights to variable or fixed payments
PDF 10 · en-pdf-010-line-017as consideration for the working of‚ or the right to work‚ mineral deposits‚ sources and
PDF 10 · en-pdf-010-line-018other natural resources. Ships and aircraft shall not be regarded as immovable property.
PDF 10 · en-pdf-010-line-019(3) The provisions of paragraph 1 shall apply to income derived from the direct use‚
PDF 10 · en-pdf-010-line-020letting‚ or use in any other form of immovable property.
PDF 10 · en-pdf-010-line-021(4) The provisions of paragraphs 1 and 3 shall also apply to the income from immovable
PDF 10 · en-pdf-010-line-022property of an enterprise.