(1) Royalties 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 “royalties” as used in this Article means payments
of any kind received as a consideration for the use of, or the right
to use, any copyright of literary, artistic or scientific work includ-
ing cinematograph films, any patent, trade mark, design or
model, plan, secret formula or process, or for information
concerning industrial, commercial or scientific experience.
(3) The provisions of paragraph 1 shall not apply if the bene-
ficial owner of the royalties, being a resident of a Contracting
State, carries on business in the other Contracting State in which
the royalties arise, through a permanent establishment situated
therein and the right or property in respect of which the royalties
are paid is effectively connected with such permanent establish-
ment. In such case the provisions of Article 7 shall apply.
(4) 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 royalties, having regard to
the use, right or information for which they are 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 according to the laws of each Contracting State,
due regard being had to the other provisions of this Agreement.
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
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 12 | 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-12/
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