tax-treaties.com
Choose agreementSOURCE EDITION
Find article

Germany – Israel · Source editionArticle 10 Dividends and Distributions by a real estate investment company

Unreviewed · applicability unverified
Source ↗

(1)

(1) Dividends paid by a company which is a resident of a Con- tracting State to a resident of the other Contracting State may be taxed in that other State.

PDF page · 7

(2)

(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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the dividends; b) 10 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.

PDF page · 7PDF page · 8

(3)

(3) Distributions made by a real estate investment company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. How- ever, such distributions may also be taxed in the Contracting State of which the real estate investment company making the distributions is a resident and according to the laws of that State, but if the beneficial owner of these distributions is a resident of the other Contracting State and holds directly less than 10 % of the capital of that company the tax so charged shall not exceed 15 % of the gross amount of the distributions. This paragraph shall not affect the taxation of the company in respect of the profits out of which the distributions are made.

PDF page · 8

(4)

(4) The term “dividends” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares, or other rights, not being debt-claims, participating in profits, 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 resident.

PDF page · 8

(5)

(5) The term “distributions by a real estate investment com- pany” means distributions a) in the case of Germany by a real estate investment company, according to subsection 1 of section 1 of the German Act on German Real Estate Stock Corporations with Listed Shares (REIT Act), b) in the case of Israel by a real estate investment company ac- cording to Article 64A2 of the Israeli Income Tax Ordinance.

PDF page · 8

(6)

(6) The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the dividends or of the distributions by a real estate investment company, being a resident of a Contract- ing State, carries on business in the other Contracting State of which the company paying the dividends or making the distribu- tions is a resident, through a permanent establishment situated therein and the holding in respect of which the dividends or dis- tributions are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.

PDF page · 8

(7)

(7) 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 situated in that other State, nor subject the company’s undistributed profits to a tax on the company’s undistributed profits, even if the dividends paid or the undistrib- uted profits consist wholly or partly of profits or income arising in such other State. This paragraph shall apply also to distributions made by a real estate investment company.

PDF page · 8
Source, edition and limits
Source edition
de-israel-2015-base | BGBl. 2015 II S. 1301 | signed 2014-08-21 | published 2015-11-26 | Signed: 2014-08-21 | Gazette publication: 2015-11-26
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 Hebrew as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. 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-israel-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 as current law. Signed 2014-08-21; consent law 2015-11-20; gazette publication 2015-11-26. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2017-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 21. August 1966, 24. September 1979, 9. Mai 2016. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. 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
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Israel R-P P: 24.05.2019 KR KR. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated 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. 1301
SHA-256
ff254953ab5239e44eff46f0a53497b4733c71eac974cf7ac823a13cb8a02bd9

Citation

Copyable citation

BGBl. 2015 II S. 1301 | de-israel-2015-base | de-israel-2015-base | BGBl. 2015 II S. 1301 | signed 2014-08-21 | published 2015-11-26 | Signed: 2014-08-21 | Gazette publication: 2015-11-26 | Article 10 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-israel-2015-base/en/articles/article-10/

Disclaimers

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

BGBl. 2015 II S. 1301

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

Source details · Preamble and protocol

Source-page links are references, not human paragraph verification.

Source, edition and limits

Choose agreement