1. If in one of the Contracting States the taxes on dividends,
interest, royalties or other items of income derived by a person
who is a resident of the other Contracting State are levied by
withholding at source, the right of the first-mentioned State to
apply the withholding of tax at the rate provided under its
domestic law shall not be affected by the provisions of this
Agreement. The tax withheld at source shall be refunded on
application by the taxpayer if according to this Agreement, there
is no or reduced source tax.
2. Refund applications must be submitted within the time
limits in accordance with the provisions of the laws of the
Contracting State in which the items of income arise.
3. Notwithstanding paragraph 1, each Contracting State shall
provide for procedures to the effect,
a) that payments of income subject under this Agreement to no
tax in the state of source may be made without deduction of
tax;
b) that payments of income subject under this Agreement to
reduced tax in the state of source may be made with deduc-
tion of tax only at the rate provided for in the relevant Article.
4. The Contracting State in which the items of income arise
may ask for a certificate by the competent authority on the
residence in the other Contracting State.
5. The competent authorities may by mutual agreement
implement the provisions of this Article and if necessary establish
other procedures for the implementation of tax reductions or
exemptions provided for under this Agreement.
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
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 28 | 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-28/
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