(1) The Contracting States undertake to
lend assistance to each other in the collec-
tion of taxes referred to in paragraph 8,
together with interest, costs, additions to
such taxes and administrative penalties,
referred to in this Article as a “revenue
claim”.The provisions of this Article are not
restricted by Article 1.
(2) An application for assistance in the
collection of a revenue claim shall include a
certification by the competent authority of
the applicant State that, under the laws of
that State, the revenue claim has been
finally determined. For the purposes of this
Article, a revenue claim is finally deter-
mined when the applicant State has the
right under its internal law to collect the
revenue claim and all administrative and
judicial rights of the taxpayer to restrain
collection in the applicant State have
lapsed or been exhausted.
(3) A revenue claim of the applicant State
that has been finally determined may be
accepted for collection by the competent
authority of the requested State and, sub-
ject to the provisions of paragraph 7, if
accepted shall be collected by the re-
quested State as though such revenue
claim were the requested State’s own
revenue claim finally determined in accord-
ance with the laws applicable to the collec-
tion of the requested State’s own taxes.
(4) Where an application for collection of
a revenue claim in respect of a taxpayer is
accepted:
a) by the Federal Republic of Germany,
the revenue claim shall be enforced by
the Federal Republic of Germany in the
same way as a revenue claim under
Federal Republic of Germany laws
against the taxpayer as of the time the
application is received; and
b) by Canada, the revenue claim shall be
treated by Canada as an amount
payable under the Income Tax Act, the
collection of which is not subject to any
restriction.
(5) Nothing in this Article shall be con-
strued as creating or providing any rights of
administrative or judicial review of the
applicant State’s finally determined rev-
enue claim by the requested State, based
on any such rights that may be available
under the laws of either Contracting State.
Proceedings relating to measures taken
under this Article by the requested State
shall be brought only before the appropri-
ate body of that State. If, at any time pend-
ing execution of a request for assistance
under this Article, the applicant State loses
the right under its internal law to collect the
revenue claim, the competent authority of
the applicant State shall promptly withdraw
the request for assistance in collection.
(6) Unless the competent authorities of
the Contracting States otherwise agree,
the ordinary costs incurred in providing
collection assistance shall be borne by the
requested State and any extraordinary
costs so incurred shall be borne by the
applicant State.
(7) A revenue claim of an applicant State
accepted for collection shall not have in the
requested State any priority accorded to
the revenue claims of the requested State
even if the recovery procedure used is the
one applicable to its own revenue claims.
(8) Notwithstanding the provisions of
Article 2, the provisions of this Article shall
apply to all categories of taxes collected by
or on behalf of the Government of a Con-
tracting State including, in the case of the
Federal Republic of Germany, the “Laen-
der”.
(9) Nothing in this Article shall be con-
strued as imposing on either Contracting
State the obligation to carry out administra-
tive measures at variance with its laws or
administrative practice or that would be
contrary to its fundamental principles of tax
policy or its public policy (ordre public).
(10) The competent authorities of the
Contracting States shall agree upon the
mode of application of this Article, includ-
ing agreement to ensure comparable levels
of assistance to each of the Contracting
States.
de-canada-2002-base | BGBl. 2002 II S. 670 | signed 2001-04-19 | published 2002-03-27 | Signed: 2001-04-19 | Gazette publication: 2002-03-27
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, multilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
The original prints German, English and French treaty and integral protocol texts in three columns. All three authentic treaty-language transcriptions are supplied here; R3 omitted French. This is NOT a full-language accuracy/completeness certification. Physical PDF page 38 is a separate German-only competent-authority agreement dated 19/20 April 2001, not an amendment or translated treaty text. No English/French version of that supplement is supplied or invented. Signature 2001-04-19 differs from edition ID/publication year 2002. No qualified human wording review, legal review, current-law or publication approval. 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-canada-2002-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 as current law. Signed 2001-04-19; consent law 2002-03-23; gazette publication 2002-03-27. Edition ID year is not a signature date. Treaty entry into force: 2002-03-28. Roster general application: 2001-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 28. März 2002. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. 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
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Kanada R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated 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. 2002 II S. 670 | de-canada-2002-base | de-canada-2002-base | BGBl. 2002 II S. 670 | signed 2001-04-19 | published 2002-03-27 | Signed: 2001-04-19 | Gazette publication: 2002-03-27 | Article 27 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-canada-2002-base/en/articles/article-27/
Source, edition and limits
Source edition
de-canada-2002-base | BGBl. 2002 II S. 670 | signed 2001-04-19 | published 2002-03-27 | Signed: 2001-04-19 | Gazette publication: 2002-03-27
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, multilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
The original prints German, English and French treaty and integral protocol texts in three columns. All three authentic treaty-language transcriptions are supplied here; R3 omitted French. This is NOT a full-language accuracy/completeness certification. Physical PDF page 38 is a separate German-only competent-authority agreement dated 19/20 April 2001, not an amendment or translated treaty text. No English/French version of that supplement is supplied or invented. Signature 2001-04-19 differs from edition ID/publication year 2002. No qualified human wording review, legal review, current-law or publication approval. 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-canada-2002-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 as current law. Signed 2001-04-19; consent law 2002-03-23; gazette publication 2002-03-27. Edition ID year is not a signature date. Treaty entry into force: 2002-03-28. Roster general application: 2001-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 28. März 2002. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. 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
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Kanada R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated 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