(2) However, such interest may also be taxed in the Contract-
ing State in which it arises and according to the laws of that
State, but if the beneficial owner of the interest is a resident of
the other Contracting State, the tax so charged shall not exceed
5 per cent of the gross amount of the interest.
(3) Notwithstanding the provisions of paragraph 2,
a) interest arising in Albania and paid in consideration of a loan
guaranteed by Germany in respect of export or foreign
direct investment or paid to the Government of the Federal
Republic of Germany, the Deutsche Bundesbank, the Kredit -
anstalt für Wiederaufbau or the DEG – Deutsche Investitions-
und Entwicklungsgesellschaft mbH shall be exempt from
Albanian tax;
b) interest arising in Germany and paid in consideration of a loan
guaranteed by Albania in respect of export or foreign direct
investment or paid to the Government of Albania or the
Central Bank of Albania shall be exempt from German tax.
(4) The term “interest” as used in this Article means income
from debt-claims of every kind, whether or not secured by
mortgage, and in particular, income from government securities
and income from bonds or debentures, including premiums
and prizes attaching to such securities, bonds or debentures.
Penalty charges for late payment shall not be regarded as
interest for the purpose of this Article.
(5) The provisions of paragraphs 1 to 3 shall not apply if the
beneficial owner of the interest, being a resident of a Contracting
State, carries on business in the other Contracting State in which
the interest arises, through a permanent establishment situated
therein, or performs in that other State independent personal
services from a fixed base situated therein, and the debt-claim
in respect of which the interest is paid is effectively connected
with such permanent establishment or fixed base. In such case
the provisions of Article 7 or Article 14, as the case may be, shall
apply.
(6) Interest shall be deemed to arise in a Contracting State
when the payer is a resident of that State. Where, however, the
person paying the interest, whether he is a resident of a
Contracting State or not, has in a Contracting State a permanent
establishment or a fixed base in connection with which the
indebtedness on which the interest is paid was incurred, and
such interest is borne by such permanent establishment or fixed
base, then such interest shall be deemed to arise in the State in
which the permanent establishment or fixed base is situated.
(7) Where, by reason of a special relationship between the
payer and the beneficial owner or between both of them and
some other person, the amount of the interest, having regard to
the debt-claim for which it is paid, exceeds the amount which
would have been agreed upon by the payer and the beneficial
owner in the absence of such relationship, the provisions of this
Article shall apply only to the last-mentioned amount. In such
case, the excess part of the payments shall remain taxable
according to the laws of each Contracting State, due regard
being had to the other provisions of this Agreement.
de-albania-2011-base | BGBl. 2011 II S. 1186 | Signed: 2010-04-06 | Gazette publication: 2011-12-08
Source form
official-publication PDF retained unchanged; reader derives from an evidenced native font-map encoding-recovery derivative, not OCR
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
German and English are supplied. The signing clause additionally identifies Albanian as authentic; Albanian is NOT present in this reader. The English text prevails in divergent interpretation of German and Albanian according to the closing clause. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-albania-2011-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2010-04-06; consent law 2011-12-05; Gazette publication 2011-12-08; treaty entry into force 2011-12-23 (retained official-article audit evidence); general application from 2012-01-01 (roster, not universal tax-specific start). Encoding-recovery method: only the source font code00 /space Unicode mapping U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyph, 278-unit advance, unchanged page content streams and 23/23 identical source/derivative page renders for this edition evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No model-generated treaty wording and no OCR.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2011 II S. 1186 | de-albania-2011-base | de-albania-2011-base | BGBl. 2011 II S. 1186 | Signed: 2010-04-06 | Gazette publication: 2011-12-08 | Article 11 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-albania-2011-base/en/articles/article-11/
Source, edition and limits
Source edition
de-albania-2011-base | BGBl. 2011 II S. 1186 | Signed: 2010-04-06 | Gazette publication: 2011-12-08
Source form
official-publication PDF retained unchanged; reader derives from an evidenced native font-map encoding-recovery derivative, not OCR
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
German and English are supplied. The signing clause additionally identifies Albanian as authentic; Albanian is NOT present in this reader. The English text prevails in divergent interpretation of German and Albanian according to the closing clause. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-albania-2011-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2010-04-06; consent law 2011-12-05; Gazette publication 2011-12-08; treaty entry into force 2011-12-23 (retained official-article audit evidence); general application from 2012-01-01 (roster, not universal tax-specific start). Encoding-recovery method: only the source font code00 /space Unicode mapping U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyph, 278-unit advance, unchanged page content streams and 23/23 identical source/derivative page renders for this edition evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No model-generated treaty wording and no OCR.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription