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Germany – Jamaica · Source editionArticle 10 Dividends

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(1)

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

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(2)

(2) However, such dividends may be taxed in the Con- tracting State of which the company paying the divi- dends is a resident, and according to the law of that State, but the tax so charged shall not exceed: (a) 10 per cent of the gross amount of the dividends if the recipient is a company (excluding partnerships) which owns directly at least 25 per cent of the shares of the company paying the dividends; (b) in all other cases, 15 per cent of the gross amount of the dividends.

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(3)

(3) Notwithstanding the provisions of paragraph (2) Jamaican tax on dividends paid to a company being a resident of the Federal Republic of Germany by a com- pany being a resident of Jamaica, at least 25 per cent of the voting shares of which is owned directly by the former company, shall not exceed 22.5 per cent of the gross amount of such dividends as long as the combined rate of Jamaican company profits tax and the additional company profits tax does not exceed 45 per cent.

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(4)

(4) Notwithstanding the provisions of paragraph (2) German tax on dividends paid to a company being a resident of Jamaica by a company being a resident of the Federal Republic of Germany, at least 25 per cent of the voting shares of which is owned directly or indirect- ly by the former company itself, or by it together with other persons controlling it or being under common con- trol with it, shall not exceed 27 per cent of the gross amount of such dividends as long as the rate of German corporation tax on distributed profits is lower than that on undistributed profits and the difference between those two rates is 15 percentage points or more.

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(5)

(5) The term “dividends” as used in this Article means income from shares, mining shares, founders’ shares or other rights, not being debt-claims, participating in prof- its, as well as income from other corporate rights assi- milated to income from shares by the taxation law of the State of which the company making the distribution is a resident, and income derived by a sleeping partner from his participation as such and distributions on certificates of an investment-trust.

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(6)

(6) The provisions of paragraphs (1) to (3) shall not apply if the recipient of the dividends, being a resident of a Contracting State, has in the other Contracting State, of which the company paying the dividends is a resident, a permanent establishment with which the hold- ing by virtue of which the dividends are paid is effec- tively connected. In such a case, the provisions of Arti- cle 7 shall apply.

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(7)

(7) Where a company which is a resident of a Con- tracting 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 to persons who are not residents of that other State, or subject the company's undistributed profits to a tax on undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income aris- ing in such other State.

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Source, edition and limits
Source edition
de-jamaica-1976-base | BGBl. 1976 II S. 1194 | signed 1974-10-08 | published 1976-07-17 | Signed: 1974-10-08 | Gazette publication: 1976-07-17
Source form
unchanged official-publication scan; separate 260-dpi local OCR machine transcription, NOT original native text
Source scope
original consent-law publication and base treaty with accompanying protocol; not current consolidated law
Retrieved
2026-09-30
Text and language scope
The original closing specifies German and English, equally authentic. No third authentic language is identified by these retained originals/audit; this is not a full-language accuracy certification. All text is unreviewed OCR, including retained wrong glyphs, punctuation, hyphens and spacing. Treaty preamble, closing, protocol, signatures, implementing law and any notes are retained separately at /review/de-jamaica-1976-base/. Exact physical-page spans and unresolved OCR at /review/de-jamaica-1976-base/evidence/. Source-page links are page references, not verified paragraph alignment.
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 1974-10-08; consent law 1976-07-14; gazette publication 1976-07-17. Edition ID year is not a signature date. Treaty entry into force: 1976-09-13. Roster general application: 1973-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 13. September 1976. 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. 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. 1976 II S. 1194
SHA-256
9c21e0ddbeda70f9067191a616ffc242edf0320f0cdfe618b53669f0f64c982c

Citation

Copyable citation

BGBl. 1976 II S. 1194 | de-jamaica-1976-base | de-jamaica-1976-base | BGBl. 1976 II S. 1194 | signed 1974-10-08 | published 1976-07-17 | Signed: 1974-10-08 | Gazette publication: 1976-07-17 | Article 10 | en | Pending human wording, completeness, source authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-jamaica-1976-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. 1976 II S. 1194

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.

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