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Germany – China · Source editionArticle 25 Mutual Agreement Prodedure

Unreviewed · applicability unverified

(1)

1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

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(2)

2. The competent authority shall endeavor, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implement- ed notwithstanding any time limits in the domestic law of the Contracting States.

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(3)

3. The competent authorities of the Contracting States shall endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agree- ment. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement.

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(4)

4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. If necessary, representatives of the competent authorities and of the responsible tax administrations may meet for an exchange of opinions.

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Source, edition and limits
Source edition
de-china-2015-base | BGBl. 2015 II S. 1647 | Signed: 2014-03-28 | Gazette publication: 2015-12-29
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 Chinese 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-china-2015-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
Citation
BGBl. 2015 II S. 1647
SHA-256
cd1af445f63ff433a95b45e466337082392d2ec4858cfcaad4629d1bd22b5d2a

Citation

Copyable citation

BGBl. 2015 II S. 1647 | de-china-2015-base | de-china-2015-base | BGBl. 2015 II S. 1647 | Signed: 2014-03-28 | Gazette publication: 2015-12-29 | Article 25 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-china-2015-base/en/articles/article-25/

Disclaimers

Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.

BGBl. 2015 II S. 1647

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

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