EN · Physical source page 25

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

PDF 25 · en-pdf-025-line-001- 25 -
PDF 25 · en-pdf-025-line-002(2) Capital represented by movable property forming part of the business property of a
PDF 25 · en-pdf-025-line-003permanent establishment which an enterprise of a Contracting State has in the other
PDF 25 · en-pdf-025-line-004Contracting State may be taxed in that other State.
PDF 25 · en-pdf-025-line-005(3) Capital represented by ships and aircraft operated by an enterprise of a Contracting
PDF 25 · en-pdf-025-line-006State in international traffic‚ and by movable property pertaining to the operation of such
PDF 25 · en-pdf-025-line-007ships and aircraft‚ shall be taxable only in that State.
PDF 25 · en-pdf-025-line-008(4) All other elements of capital of a resident of a Contracting State shall be taxable only
PDF 25 · en-pdf-025-line-009in that State.
PDF 25 · en-pdf-025-line-010Article 22
PDF 25 · en-pdf-025-line-011Elimination of Double Taxation
PDF 25 · en-pdf-025-line-012(1) In the case of a resident of the Federal Republic of Germany‚ tax shall be determined
PDF 25 · en-pdf-025-line-013as follows:
PDF 25 · en-pdf-025-line-014a)
PDF 25 · en-pdf-025-line-015Unless foreign tax credit is to be allowed under subparagraph (b)‚ there shall
PDF 25 · en-pdf-025-line-016be exempted from the assessment basis of the German tax any item of income
PDF 25 · en-pdf-025-line-017arising in South Africa and any item of capital situated within South Africa
PDF 25 · en-pdf-025-line-018which‚ according to this Agreement‚ may be taxed in South Africa. The
PDF 25 · en-pdf-025-line-019Federal Republic of Germany‚ however‚ retains the right to take into account
PDF 25 · en-pdf-025-line-020in the determination of its rate of tax the items of income and capital so
PDF 25 · en-pdf-025-line-021exempted. In the case of items of income from dividends the preceding
PDF 25 · en-pdf-025-line-022provision shall apply only to such dividends as are paid to a company (not
PDF 25 · en-pdf-025-line-023including partnerships) being a resident of the Federal Republic of Germany
PDF 25 · en-pdf-025-line-024by a company being a resident of South Africa at least 10 per cent of the
PDF 25 · en-pdf-025-line-025capital of which is owned directly by the German company and which were