EN · Physical source page 18

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

PDF 18 · en-pdf-018-line-001- 18 -
PDF 18 · en-pdf-018-line-002such relationship‚ the provisions of this Article shall apply only to the last-mentioned
PDF 18 · en-pdf-018-line-003amount. In such case‚ the excess part of the payments shall remain taxable according to
PDF 18 · en-pdf-018-line-004the laws of each Contracting State‚ due regard being had to the other provisions of this
PDF 18 · en-pdf-018-line-005Agreement.
PDF 18 · en-pdf-018-line-006Article 13
PDF 18 · en-pdf-018-line-007Capital Gains
PDF 18 · en-pdf-018-line-008(1) Gains derived by a resident of a Contracting State from the alienation of immovable
PDF 18 · en-pdf-018-line-009property situated in the other Contracting State may be taxed in that other State.
PDF 18 · en-pdf-018-line-010(2) Gains from the alienation of shares and similar rights in a company‚ the assets of
PDF 18 · en-pdf-018-line-011which consist directly or indirectly principally of immovable property situated in a
PDF 18 · en-pdf-018-line-012Contracting State‚ may be taxed in that State.
PDF 18 · en-pdf-018-line-013(3) Gains from the alienation of movable property forming part of the business property
PDF 18 · en-pdf-018-line-014of a permanent establishment which an enterprise of a Contracting State has in the other
PDF 18 · en-pdf-018-line-015Contracting State, including such gains from the alienation of such a permanent
PDF 18 · en-pdf-018-line-016establishment (alone or with the whole enterprise)‚ may be taxed in that other State.
PDF 18 · en-pdf-018-line-017(4) Gains of an enterprise of a Contracting State from the alienation of ships or aircraft
PDF 18 · en-pdf-018-line-018operated in international traffic or movable property pertaining to the operation of such
PDF 18 · en-pdf-018-line-019ships or aircraft‚ shall be taxable only in that State.
PDF 18 · en-pdf-018-line-020(5) Gains from the alienation of any property other than that referred to in the preceding
PDF 18 · en-pdf-018-line-021paragraphs‚ shall be taxable only in the Contracting State of which the alienator is a
PDF 18 · en-pdf-018-line-022resident.