1. Nationals of a Contracting State shall not be subjected in
the other Contracting State to any taxation or any requirement
connected therewith, which is other or more burdensome than
the taxation and connected requirements to which nationals of
that other State in the same circumstances, in particular with re-
spect to residence, are or may be subjected. This provision shall,
notwithstanding the provisions of Article 1, also apply to persons
who are not residents of one or both of the Contracting States.
2. Stateless persons who are residents of a Contracting State
shall not be subjected in either Contracting State to any taxation
or any requirement connected therewith, which is other or more
burdensome than the taxation and connected requirements to
which nationals of the State concerned in the same circum-
stances, in particular with respect to residence, are or may be
subjected.
3. The taxation on a permanent establishment which an en-
terprise of a Contracting State has in the other Contracting State
shall not be less favourably levied in that other State than the tax-
ation levied on enterprises of that other State carrying on the
same activities. This provision shall not be construed as obliging
a Contracting State to grant to residents of the other Contracting
State any personal allowances, reliefs and reductions for taxation
purposes on account of civil status or family responsibilities
which it grants to its own residents.
4. Except where the provisions of paragraph 1 of Article 9,
paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, in-
terest, royalties and other disbursements paid by an enterprise
of a Contracting State to a resident of the other Contracting State
shall, for the purpose of determining the taxable profits of such
enterprise, be deductible under the same conditions as if they
had been paid to a resident of the first-mentioned State. Similar-
ly, any debts of an enterprise of a Contracting State to a resident
of the other Contracting State shall, for the purpose of determin-
ing the taxable capital of such enterprise, be deductible under
the same conditions as if they had been contracted to a resident
of the first-mentioned State.
5. Enterprises of a Contracting State, the capital of which is
wholly or partly owned or controlled, directly or indirectly, by one
or more residents of the other Contracting State, shall not be
subjected in the first-mentioned State to any taxation or any re-
quirement connected therewith which is other or more burden-
some than the taxation and connected requirements to which
other similar enterprises of the first-mentioned State are or may
be subjected.
de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Armenian as authentic; that third version is NOT present in this reader. 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-armenia-2017-base/. PDF page links identify pages, not verified paragraph correspondence.
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. 2017 II S. 1077 | de-armenia-2017-base | de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27 | Article 23 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-armenia-2017-base/en/articles/article-23/
Source, edition and limits
Source edition
de-armenia-2017-base | BGBl. 2017 II S. 1077 | Signed: 2016-06-29 | Gazette publication: 2017-07-27
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Armenian as authentic; that third version is NOT present in this reader. 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-armenia-2017-base/. PDF page links identify pages, not verified paragraph correspondence.
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