EN · Physical source page 29

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

PDF 29 · en-pdf-029-line-001- 29 -
PDF 29 · en-pdf-029-line-002than the taxation levied on enterprises of that other State carrying on the same activities.
PDF 29 · en-pdf-029-line-003This provision shall not be construed as obliging a Contracting State to grant to residents
PDF 29 · en-pdf-029-line-004of the other Contracting State any personal allowances‚ reliefs and reductions for taxation
PDF 29 · en-pdf-029-line-005purposes which it grants only to its own residents.
PDF 29 · en-pdf-029-line-006(3) Except where the provisions of paragraph 1 of Article 9‚ paragraph 5 of Article 11‚ or
PDF 29 · en-pdf-029-line-007paragraph 5 of Article 12‚ apply‚ interest‚ royalties and other disbursements paid by an
PDF 29 · en-pdf-029-line-008enterprise of a Contracting State to a resident of the other Contracting State shall‚ for the
PDF 29 · en-pdf-029-line-009purpose of determining the taxable profits of such enterprise‚ be deductible under the
PDF 29 · en-pdf-029-line-010same conditions as if they had been paid to a resident of the first-mentioned State.
PDF 29 · en-pdf-029-line-011Similarly‚ any debts of an enterprise of a Contracting State to a resident of the other
PDF 29 · en-pdf-029-line-012Contracting State shall‚ for the purpose of determining the taxable capital of such
PDF 29 · en-pdf-029-line-013enterprise‚ be deductible under the same conditions as if they had been contracted to a
PDF 29 · en-pdf-029-line-014resident of the first-mentioned State.
PDF 29 · en-pdf-029-line-015(4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or
PDF 29 · en-pdf-029-line-016controlled‚ directly or indirectly‚ by one or more residents of the other Contracting State‚
PDF 29 · en-pdf-029-line-017shall not be subjected in the first-mentioned State to any taxation or any requirement
PDF 29 · en-pdf-029-line-018connected therewith which is other or more burdensome than the taxation and connected
PDF 29 · en-pdf-029-line-019requirements to which other similar enterprises of the first-mentioned State are or may be
PDF 29 · en-pdf-029-line-020subjected.
PDF 29 · en-pdf-029-line-021(5) Nothing contained in this Article shall prevent South Africa from imposing on the
PDF 29 · en-pdf-029-line-022profits attributable to a permanent establishment in South Africa of a company‚ which is
PDF 29 · en-pdf-029-line-023a resident of the Federal Republic of Germany‚ a tax at a rate which does not exceed the
PDF 29 · en-pdf-029-line-024rate of normal tax on profits of companies by more than five percentage points.
PDF 29 · en-pdf-029-line-025(6) The provisions of this Article shall‚ notwithstanding the provisions of Article 2‚ apply
PDF 29 · en-pdf-029-line-026to taxes of every kind and description.