EN · Physical source page 15

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 15. Page-number furniture is retained. Source coordinate order, not a facsimile or human-verified typography.

PDF 15 · en-pdf-015-line-001- 15 -
PDF 15 · en-pdf-015-line-002of which the company making the distribution is a resident. The term ”dividends”
PDF 15 · en-pdf-015-line-003includes also income derived by a silent partner (”stiller Gesellschafter”) from that
PDF 15 · en-pdf-015-line-004partner’s participation as such or from a ”partiarisches Darlehen”‚ ”Gewinnobligationen”
PDF 15 · en-pdf-015-line-005or similar payments and distributions on certificates of an investment fund or investment
PDF 15 · en-pdf-015-line-006trust.
PDF 15 · en-pdf-015-line-007(5) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
PDF 15 · en-pdf-015-line-008dividends‚ being a resident of a Contracting State‚ carries on business in the other
PDF 15 · en-pdf-015-line-009Contracting State of which the company paying the dividends is a resident‚ through a
PDF 15 · en-pdf-015-line-010permanent establishment situated therein and the holding in respect of which the
PDF 15 · en-pdf-015-line-011dividends are paid is effectively connected with such permanent establishment. In such
PDF 15 · en-pdf-015-line-012case‚ the provisions of Article 7 shall apply.
PDF 15 · en-pdf-015-line-013(6) Where a company which is a resident of a Contracting State derives profits or income
PDF 15 · en-pdf-015-line-014from the other Contracting State‚ that other State may not impose any tax on the
PDF 15 · en-pdf-015-line-015dividends paid by the company‚ except insofar as such dividends are paid to a resident of
PDF 15 · en-pdf-015-line-016that other State or insofar as the holding in respect of which the dividends are paid is
PDF 15 · en-pdf-015-line-017effectively connected with a permanent establishment situated in that other State‚ nor
PDF 15 · en-pdf-015-line-018subject the company’s undistributed profits to a tax on the company’s undistributed
PDF 15 · en-pdf-015-line-019profits‚ even if the dividends paid or the undistributed profits consist wholly or partly of
PDF 15 · en-pdf-015-line-020profits or income arising in such other State.
PDF 15 · en-pdf-015-line-021Article 11
PDF 15 · en-pdf-015-line-022Interest
PDF 15 · en-pdf-015-line-023(1) Interest arising in a Contracting State and paid to a resident of the other Contracting
PDF 15 · en-pdf-015-line-024State shall be taxable only in that other State‚ provided such resident is the beneficial
PDF 15 · en-pdf-015-line-025owner of the interest.