Published treaty languages: German and English. Original closing on physical page 21 declares both texts equally authoritative. Both bodies come exclusively from the original 2011 PDF. No third language, translation or cross-language paragraph alignment is inferred. English interface; legal source containers carry their own language.
Signed at Dublin 2011-03-30; consent law 2011-11-01; gazette publication 2011-11-07. Treaty entry 2012-11-28, not application; entry notice dated 2013-02-11, published 2013-03-20. Article 32(2) general application from 2013-01-01 is qualified by tax-specific rules and transitional paragraphs 32(3)–(5).
Historical original edition only. Later amending protocols signed 2014-12-03 and 2021-01-19 and a 2025 official consolidation are documented in the cached BMF article; none of their amended wording is imported here. The cache is not fresh currentness proof. This new edition does not replace the held 2025 intake or override its central audit. Later amendments, MLI effects and present-day applicability are not certified.
Original PDF SHA-256: cb0eafbd040330600bb8c68e415d95c7360a5f9eebf1ddf2a25157b0705e3e7c
Source component only, not a treaty article. English interface; original text in English. Page links are not paragraph alignment.
Physical page 26 · printed 1067
Joint Declaration
by the Federal Republic of Germany
and Ireland
on the occasion of the signing on 30 March 2011 in Dublin
of the Agreement
between the Federal Republic of Germany
and Ireland
for the Avoidance of Double Taxation
and the Prevention of Fiscal Evasion
with respect to Taxes on Income and on Capital
The Federal Republic of Germany and Ireland, on the occa sion
of the signing on 30 March 2011 in Dublin of the new Agreement
between the Federal Republic of Germany and Ireland for the
Avoidance of Double Taxation and the Prevention of Fiscal
Evasion with Respect to Taxes on Income and on Capital and
with regard to the improper use of that Agreement,
Have reached the following understanding:
Improper use of the Agreement
Having regard to paragraphs 7 to 12 of the July 2008 version of
the Commentary to Article 1 of the OECD model tax convention,
it is understood that this Agreement shall not be interpreted
to mean that a Contracting State is prevented from applying
its domestic legal provisions on the prevention of tax evasion or
tax avoidance where those provisions are used to challenge
arrangements which constitute an abuse of the Agreement.
It is further understood that an abuse of the Agreement takes
place where a main purpose for entering into certain transactions
or arrangements is to secure a more favourable tax position and
obtaining that more favourable treatment in these circumstances
would be contrary to the object and purpose of the relevant
provisions of the Agreement.
This Joint Declaration is signed in duplicate at Dublin, in the
German and English languages, this 30thday of March, 2011.