(1) Interest arising in a Contracting State and beneficially
owned by a resident of the other Contracting State shall be tax-
able only in that other State.
(2) The term “interest” as used in this Article means income
from debt-claims of every kind, whether or not secured by mort-
gage, and in particular, income from government securities and
income from bonds or debentures, including premiums and
prizes attaching to such securities, bonds or debentures. Penal-
ty charges for late payment shall not be regarded as interest for
the purpose of this Article.
(3) The provisions of paragraph (1) shall not apply if the ben-
eficial owner of the interest, being a resident of a Contracting
State, carries on business in the other Contracting State in which
the interest arises, through a permanent establishment situated
therein and the debt-claim in respect of which the interest is paid
is effectively connected with such permanent establishment. In
such case the provisions of Article 7 shall apply.
(4) Interest shall be deemed to arise in a Contracting State
when the payer is that State, a Land or any political subdivision
or local authority thereof or a resident of that State. Where, how-
ever, the person paying the interest, whether he is a resident of a
Contracting State or not, has in a Contracting State a permanent
establishment in connection with which the indebtedness on
which the interest is paid was incurred, and such interest is borne
by such permanent establishment, then such interest shall be
deemed to arise in the State in which the permanent establish-
ment is situated.
(5) Where, by reason of a special relationship between the
payer and the beneficial owner or between both of them and
some other person, the amount of the interest, having regard to
the debt-claim for which it is paid, exceeds the amount which
would have been agreed upon by the payer and the beneficial
owner in the absence of such relationship, the provisions of this
Article shall apply only to the last-mentioned amount. In such
case, the excess part of the payments shall remain taxable ac-
cording to the laws of each Contracting State, due regard being
had to the other provisions of this Agreement.
de-cyprus-2011-base | BGBl. 2011 II S. 1068 | Signed: 2011-02-18 | Gazette publication: 2011-11-07
Source form
official-publication PDF retained unchanged; reader derives from an evidenced native font-map encoding-recovery derivative, not OCR
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
The original signing clause identifies German, Greek and English as authentic. Only German and English are supplied; the authentic Greek version is NOT included. The clause gives English precedence in divergent interpretation of the German and Greek texts. 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-cyprus-2011-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2011-02-18; consent law 2011-11-01; Gazette publication 2011-11-07; treaty entry into force UNRESOLVED in pinned audit (retained official-article audit evidence); general application from 2012-01-01 (roster, not universal tax-specific start). Encoding-recovery method: only independently evidenced source font code00 /space Unicode mappings U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyphs, 278-unit advances, unchanged decoded page content streams and 21/21 identical page renders evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No generated treaty wording and no OCR.
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. Original base edition only; current law NOT verified. Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. KNOWN LATER AMENDMENT OMITTED: protocol signed 2021-02-19, entry 2021-12-08, general application 2022-01-01 per pinned audit; not incorporated. 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
Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. KNOWN LATER AMENDMENT OMITTED: protocol signed 2021-02-19, entry 2021-12-08, general application 2022-01-01 per pinned audit; not incorporated. 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. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2021-02-19; entry into force: 2021-12-08; general application from: 2022-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2011 II S. 1068 | de-cyprus-2011-base | de-cyprus-2011-base | BGBl. 2011 II S. 1068 | Signed: 2011-02-18 | Gazette publication: 2011-11-07 | Article 11 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-cyprus-2011-base/en/articles/article-11/
Source, edition and limits
Source edition
de-cyprus-2011-base | BGBl. 2011 II S. 1068 | Signed: 2011-02-18 | Gazette publication: 2011-11-07
Source form
official-publication PDF retained unchanged; reader derives from an evidenced native font-map encoding-recovery derivative, not OCR
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
The original signing clause identifies German, Greek and English as authentic. Only German and English are supplied; the authentic Greek version is NOT included. The clause gives English precedence in divergent interpretation of the German and Greek texts. 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-cyprus-2011-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2011-02-18; consent law 2011-11-01; Gazette publication 2011-11-07; treaty entry into force UNRESOLVED in pinned audit (retained official-article audit evidence); general application from 2012-01-01 (roster, not universal tax-specific start). Encoding-recovery method: only independently evidenced source font code00 /space Unicode mappings U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyphs, 278-unit advances, unchanged decoded page content streams and 21/21 identical page renders evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No generated treaty wording and no OCR.
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. Original base edition only; current law NOT verified. Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. KNOWN LATER AMENDMENT OMITTED: protocol signed 2021-02-19, entry 2021-12-08, general application 2022-01-01 per pinned audit; not incorporated. 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
Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. KNOWN LATER AMENDMENT OMITTED: protocol signed 2021-02-19, entry 2021-12-08, general application 2022-01-01 per pinned audit; not incorporated. 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. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2021-02-19; entry into force: 2021-12-08; general application from: 2022-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription