(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 Contracting State.
(2) However, dividends paid by a company which is a resident
of a Contracting State may also be taxed in that Contracting
State according to the laws of that Contracting State, but if the
beneficial owner of the dividends is a resident of the other Con-
tracting 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) that has
owned directly, for the period of six months ending on the
date on which entitlement to the dividends is determined, at
least 10 per cent of the voting shares of the company paying
the dividends;
b) 15 per cent of the gross amount of the dividends in all other
cases.
(3) Notwithstanding the provisions of paragraph 2, dividends
shall not be taxed in the Contracting State of which the company
paying the dividends is a resident if the beneficial owner of the
dividends is a resident of the other Contracting State and is a
company (other than a partnership) that has owned directly, for
the period of eighteen months ending on the date on which en-
titlement to the dividends is determined, at least 25 per cent of
the voting shares of the company paying the dividends.
(5) 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, as well as other income which is subject-
ed to the same taxation treatment as income from shares by the
tax laws of the Contracting State of which the company making
the distribution is a resident.
(6) The provisions of paragraphs 1, 2 and 3 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 and the holding in
respect of which the dividends are paid is effectively connected
with such permanent establishment. In such case the provisions
of Article 7 shall apply.
(7) Where a company which is a resident of a Contracting
State derives profits or income from the other Contracting State,
that other Contracting State may not impose any tax on the
dividends paid by the company, except insofar as such divi-
dends are paid to a resident of that other Contracting 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 Contracting State, nor subject the company’s undis-
tributed profits to a tax on the company’s undistributed profits,
even if the dividends paid or the undistributed profits consist
wholly or partly of profits or income arising in such other Con-
tracting State.
de-japan-2016-base | BGBl. 2016 II S. 956 | Signed: 2015-12-17 | Gazette publication: 2016-07-25
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 Japanese as authentic; that third version is NOT present in this reader. 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-japan-2016-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. 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
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: 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): BEPS-MLI; general application from: 2026-01-01
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2016 II S. 956 | de-japan-2016-base | de-japan-2016-base | BGBl. 2016 II S. 956 | Signed: 2015-12-17 | Gazette publication: 2016-07-25 | Article 10 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-japan-2016-base/en/articles/article-10/
Source, edition and limits
Source edition
de-japan-2016-base | BGBl. 2016 II S. 956 | Signed: 2015-12-17 | Gazette publication: 2016-07-25
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 Japanese as authentic; that third version is NOT present in this reader. 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-japan-2016-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. 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
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: 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): BEPS-MLI; general application from: 2026-01-01
Text language and status
en · authentic-language-transcription · machine-transcription