EN · Physical source page 30

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.

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EN original PDF · Both source hashes and provenance · Complete 2008 source supplements

Complete native lines of physical PDF page 30. Page-number furniture is retained. Source coordinate order, not a facsimile or human-verified typography.

PDF 30 · en-pdf-030-line-001- 30 -
PDF 30 · en-pdf-030-line-002Article 24
PDF 30 · en-pdf-030-line-003Mutual Agreement Procedure
PDF 30 · en-pdf-030-line-004(1) Where a person considers that the actions of one or both of the Contracting States
PDF 30 · en-pdf-030-line-005result or will result for that person in taxation not in accordance with the provisions of this
PDF 30 · en-pdf-030-line-006Agreement‚ that person may‚ irrespective of the remedies provided by the domestic law
PDF 30 · en-pdf-030-line-007of those States‚ present a case to the competent authority of the Contracting State of
PDF 30 · en-pdf-030-line-008which the person is a resident or‚ if the case comes under paragraph 1 of Article 23‚ to
PDF 30 · en-pdf-030-line-009that of the Contracting State of which the person is a national. The case must be presented
PDF 30 · en-pdf-030-line-010within three years from the first notification of the action resulting in taxation not in
PDF 30 · en-pdf-030-line-011accordance with the provisions of this Agreement.
PDF 30 · en-pdf-030-line-012(2) The competent authority shall endeavour‚ if the objection appears to it to be justified
PDF 30 · en-pdf-030-line-013and if it is not itself able to arrive at a satisfactory solution‚ to resolve the case by mutual
PDF 30 · en-pdf-030-line-014agreement with the competent authority of the other Contracting State‚ with a view to the
PDF 30 · en-pdf-030-line-015avoidance of taxation which is not in accordance with this Agreement. Any agreement
PDF 30 · en-pdf-030-line-016reached shall be implemented notwithstanding any time limits in the domestic law of the
PDF 30 · en-pdf-030-line-017Contracting States.
PDF 30 · en-pdf-030-line-018(3) The competent authorities of the Contracting States shall endeavour to resolve by
PDF 30 · en-pdf-030-line-019mutual agreement any difficulties or doubts arising as to the interpretation or application
PDF 30 · en-pdf-030-line-020of this Agreement. They may also consult together for the avoidance of double taxation
PDF 30 · en-pdf-030-line-021in cases not provided for in this Agreement.
PDF 30 · en-pdf-030-line-022(4) If the taxation of income in a Contracting State is effected by way of a withholding tax
PDF 30 · en-pdf-030-line-023at source‚ and if this taxation is limited by the provisions of this Agreement‚ the
PDF 30 · en-pdf-030-line-024application of this tax reduction or exemption shall be governed by the national law of
PDF 30 · en-pdf-030-line-025that State in conjunction with the procedures agreed upon for this purpose between the
PDF 30 · en-pdf-030-line-026competent authorities of the two Contracting States.