EN · Physical source page 28

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

PDF 28 · en-pdf-028-line-001- 28 -
PDF 28 · en-pdf-028-line-002was made and all legal requirements under the domestic law of the
PDF 28 · en-pdf-028-line-003notifying State for the notification to take effect have been fulfilled.
PDF 28 · en-pdf-028-line-004(2) In the case of a resident of South Africa‚ subject to the provisions of the law of South
PDF 28 · en-pdf-028-line-005Africa regarding the deduction from tax payable in South Africa of tax payable in any
PDF 28 · en-pdf-028-line-006country other than South Africa (which shall not affect the general principle hereof)‚
PDF 28 · en-pdf-028-line-007German tax paid by residents of South Africa in respect of income taxable in the Federal
PDF 28 · en-pdf-028-line-008Republic of Germany‚ in accordance with the provisions of this Agreement‚ shall be
PDF 28 · en-pdf-028-line-009deducted from the taxes due according to South African fiscal law. Such deduction shall
PDF 28 · en-pdf-028-line-010not‚ however‚ exceed an amount which bears to the total South African tax payable the
PDF 28 · en-pdf-028-line-011same ratio as the income concerned bears to the total income.
PDF 28 · en-pdf-028-line-012(3) For the purposes of this Article‚ profits‚ income or gains of a resident of a Contracting
PDF 28 · en-pdf-028-line-013State (with the exception of income mentioned in paragraph 2 of Article 10 and in
PDF 28 · en-pdf-028-line-014paragraphs 2 and 3 of Article 17) shall be deemed to arise from sources in the other
PDF 28 · en-pdf-028-line-015Contracting State if they are taxed in that other State in accordance with this Agreement.
PDF 28 · en-pdf-028-line-016Article 23
PDF 28 · en-pdf-028-line-017Non-discrimination
PDF 28 · en-pdf-028-line-018(1) Nationals of a Contracting State shall not be subjected in the other Contracting State
PDF 28 · en-pdf-028-line-019to any taxation or any requirement connected therewith which is other or more
PDF 28 · en-pdf-028-line-020burdensome than the taxation and connected requirements to which nationals of that other
PDF 28 · en-pdf-028-line-021State in the same circumstances‚ especially with respect to residence‚ are or may be
PDF 28 · en-pdf-028-line-022subjected. This provision shall‚ notwithstanding the provisions of Article 1‚ also apply to
PDF 28 · en-pdf-028-line-023persons who are not residents of one or both of the Contracting States.
PDF 28 · en-pdf-028-line-024(2) The taxation on a permanent establishment which an enterprise of a Contracting State
PDF 28 · en-pdf-028-line-025has in the other Contracting State shall not be less favourably levied in that other State