(1) For the purposes of this Agreement,
unless the context otherwise requires:
a) the term “Canada” when used in a geo-
graphical sense, means the territory of
Canada, including:
aa) any area beyond the territorial sea
of Canada which, in accordance
with international law and the laws
of Canada, is an area within which
Canada may exercise rights with
respect to the seabed and subsoil
and their natural resources;
bb) the sea and airspace above every
area referred to in (aa) in respect of
any activity carried on in connec-
tion with the exploration for or the
exploitation of the natural re-
sources referred to therein;
b) the term “Federal Republic of Ger-
many” when used in a geographical
sense, means the territory of the Feder-
al Republic of Germany as well as the
area of the seabed, its subsoil and the
superjacent water column adjacent to
the territorial sea, wherein the Federal
Republic of Germany exercises sover-
eign rights and jurisdiction in conform-
ity with international law and its nation-
al legislation for the purpose of explor-
ing, exploiting, conserving and manag-
ing the living and non-living natural
resources;
c) the terms “a Contracting State” and
“the other Contracting State” mean, as
the context requires, Canada or the
Federal Republic of Germany;
d) the term “person” includes an individual
and a company;
e) the term “company” means any body
corporate or any other entity which is
treated as a body corporate for tax pur-
poses;
f)
the terms “enterprise of a Contracting
State” and “enterprise of the other Con-
tracting State” mean respectively an
enterprise carried on by a resident of a
Contracting State and an enterprise
carried on by a resident of the other
Contracting State;
g) the term “national” means:
aa) in respect of Canada, any individ-
ual possessing the nationality of
Canada and any legal person,
partnership or association deriving
its status as such from the law in
force in Canada;
bb) in respect of the Federal Republic
of Germany, any German within
the meaning of the Basic Law for
the Federal Republic of Germany
and any legal person, partnership
and association deriving its status
as such from the law in force in the
Federal Republic of Germany;
h) the term “competent authority” means:
aa) in the case of Canada, the Minister
of National Revenue or the Minis-
ter’s authorized representative,
bb) in the case of the Federal Republic
of Germany, the Federal Minister
of Finance or the Minister’s del-
egate;
i)
the term “international traffic” means
any voyage of a ship or aircraft oper-
ated by an enterprise of a Contracting
State, except where the principal pur-
pose of the voyage is to transport pas-
sengers or property between places
within the other Contracting State.
(2) As regards the application of the
Agreement by a Contracting State at any
time, any term not defined therein shall,
unless the context otherwise requires, have
the meaning which it has at that time under
the law of that State concerning the taxes
to which the Agreement applies, any mean-
ing under the applicable tax laws of that
State prevailing over a meaning given to
the term under other laws of that State.
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 3 | 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-3/
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