EN · Physical source page 16

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

PDF 16 · en-pdf-016-line-001- 16 -
PDF 16 · en-pdf-016-line-002(2) The term ”interest” as used in this Article means income from debt-claims of every kind‚
PDF 16 · en-pdf-016-line-003whether or not secured by mortgage and whether or not carrying a right to participate in the
PDF 16 · en-pdf-016-line-004debtor’s profits‚ and in particular‚ income from government securities and income from
PDF 16 · en-pdf-016-line-005bonds or debentures‚ including premiums and prizes attaching to such securities‚ bonds or
PDF 16 · en-pdf-016-line-006debentures. Penalty charges for late payment shall not be regarded as interest for the
PDF 16 · en-pdf-016-line-007purposes of this Article. However‚ the term ”interest” shall not include income dealt with in
PDF 16 · en-pdf-016-line-008Article 10.
PDF 16 · en-pdf-016-line-009(3) The provisions of paragraph 1 shall not apply if the beneficial owner of the interest‚
PDF 16 · en-pdf-016-line-010being a resident of a Contracting State‚ carries on business in the other Contracting State in
PDF 16 · en-pdf-016-line-011which the interest arises‚ through a permanent establishment situated therein and the
PDF 16 · en-pdf-016-line-012debt-claim in respect of which the interest is paid is effectively connected with such
PDF 16 · en-pdf-016-line-013permanent establishment. In such case‚ the provisions of Article 7 shall apply.
PDF 16 · en-pdf-016-line-014(4) Interest shall be deemed to arise in a Contracting State when the payer is a resident of
PDF 16 · en-pdf-016-line-015that State. Where‚ however‚ the person paying the interest‚ whether that person is a resident
PDF 16 · en-pdf-016-line-016of a Contracting State or not‚ has in a Contracting State a permanent establishment in
PDF 16 · en-pdf-016-line-017connection with which the indebtedness on which the interest is paid was incurred‚ and such
PDF 16 · en-pdf-016-line-018interest is borne by such permanent establishment‚ then such interest shall be deemed to
PDF 16 · en-pdf-016-line-019arise in the State in which the permanent establishment is situated.
PDF 16 · en-pdf-016-line-020(5) Where‚ by reason of a special relationship between the payer and the beneficial owner or
PDF 16 · en-pdf-016-line-021between both of them and some other person‚ the amount of the interest‚ having regard to
PDF 16 · en-pdf-016-line-022the debt-claim for which it is paid‚ exceeds the amount which would have been agreed upon
PDF 16 · en-pdf-016-line-023by the payer and the beneficial owner in the absence of such relationship‚ the provisions of
PDF 16 · en-pdf-016-line-024this Article shall apply only to the last-mentioned amount. In such case‚ the excess part of
PDF 16 · en-pdf-016-line-025the payments shall remain taxable according to the laws of each Contracting State‚ due
PDF 16 · en-pdf-016-line-026regard being had to the other provisions of this Agreement.