(1) Capital represented by immovable property referred to in
Article 6, owned by a resident of a Contracting State and situ -
ated in the other Contracting State, may be taxed in that other
State.
(2) Capital represented by movable property forming part of
the business property of a permanent establishment which an
enterprise of a Contracting State has in the other Contracting
State may be taxed in that other State.
(3) Capital represented by ships and aircraft operated in inter-
national traffic, and by boats engaged in inland waterways trans-
port, and by movable property pertaining to the operation of such
ships and aircraft and boats, shall be taxable only in the Con-
tracting State in which the place of effective management of the
enterprise is situated.
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 21 | 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-21/
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