(1) Dividends paid by a company which is a resident of a
Contracting State to a resident of the other Contracting State
may be taxed in that other State.
(2) However, such dividends may also be taxed in the Con-
tracting State of which the company paying the dividends is a
resident and according to the laws of that State, but if the ben-
eficial owner of the dividends is a resident of the other Contract-
ing State, the tax so charged shall not exceed:
a) 5 per cent of the gross amount of the dividends if the bene-
ficial owner is a company (other than a partnership) which
holds directly at least 10 per cent of the capital of the com-
pany paying the dividends;
b) 15 per cent of the gross amount of the dividends in all other
cases.
This paragraph shall not affect the taxation of the company in
respect of the profits out of which the dividends are paid.
(3) The term “dividends” as used in this Article means
income from shares or other income which is subjected to the
same taxation treatment as income from shares by the laws of
the State of which the company making the distribution is a res-
ident and distributions on certificates of an investment fund or
investment trust.
(4) The provisions of paragraphs 1 and 2 shall not apply if the
beneficial owner of the dividends, being a resident of a Con-
tracting State, carries on business in the other Contracting
State of which the company paying the dividends is a resident,
through a permanent establishment situated therein, or per-
forms in that other State, independent personal services from a
fixed base situated therein, and the holding in respect of which
the dividends are paid is effectively connected with such per-
manent establishment or fixed base. In such case the pro-
visions of Article 7 or Article 14, as the case may be, shall apply.
(5) Where a company which is a resident of a Contracting
State derives profits or income from the other Contracting
State, that other State may not impose any tax on the dividends
paid by the company, except insofar as such dividends are paid
to a resident of that other State or insofar as the holding in
respect of which the dividends are paid is effectively connected
with a permanent establishment or a fixed base situated in that
other State, nor subject the company’s undistributed profits to
a tax on the company’s undistributed profits, even if the divi-
dends paid or the undistributed profits consist wholly or partly
of profits or income arising in such other State.
de-ghana-2006-base | BGBl. 2006 II S. 1018 | Signed: 2004-08-12 | Gazette publication: 2006-12-07
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
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-ghana-2006-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. No later amendment identified in roster I.1 or cached/fetched BMF article. The October1 HTML section was checked and matches the cache; this is not exhaustive currentness certification. Ghana is not listed in roster I.2 as of2026-01-01. A country-page omission does not prove absence of all later MLI/legal developments.
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: No later amendment identified in roster I.1 or cached/fetched BMF article. The October1 HTML section was checked and matches the cache; this is not exhaustive currentness certification. Ghana is not listed in roster I.2 as of2026-01-01. A country-page omission does not prove absence of all later MLI/legal developments.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2006 II S. 1018 | de-ghana-2006-base | de-ghana-2006-base | BGBl. 2006 II S. 1018 | Signed: 2004-08-12 | Gazette publication: 2006-12-07 | Article 10 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-ghana-2006-base/en/articles/article-10/
Source, edition and limits
Source edition
de-ghana-2006-base | BGBl. 2006 II S. 1018 | Signed: 2004-08-12 | Gazette publication: 2006-12-07
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
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-ghana-2006-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. No later amendment identified in roster I.1 or cached/fetched BMF article. The October1 HTML section was checked and matches the cache; this is not exhaustive currentness certification. Ghana is not listed in roster I.2 as of2026-01-01. A country-page omission does not prove absence of all later MLI/legal developments.
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: No later amendment identified in roster I.1 or cached/fetched BMF article. The October1 HTML section was checked and matches the cache; this is not exhaustive currentness certification. Ghana is not listed in roster I.2 as of2026-01-01. A country-page omission does not prove absence of all later MLI/legal developments.
Text language and status
en · authentic-language-transcription · machine-transcription