(1) The competent authorities of the Contracting States shall
exchange such information as is foreseeably relevant for carrying
out the provisions of this Agreement or to the administration or
enforcement of the domestic laws concerning taxes of every kind
and description imposed on behalf of the Contracting States, of
any federal state (Land) thereof, or of any political subdivision or
local authority thereof, insofar as the taxation thereunder is not
contrary to the Agreement. The exchange of information is not
restricted by Articles 1 and 2.
(2) Any information received under paragraph 1 by a Contract-
ing State shall be treated as secret in the same manner as infor-
mation obtained under the domestic laws of that Contracting
State and shall be disclosed only to persons or authorities
(including courts and administrative bodies) concerned with the
assessment or collection of, the enforcement or prosecution in
respect of, the determination of appeals in relation to the taxes
referred to in paragraph 1, or the oversight of the above. Such
persons or authorities shall use the information only for such pur-
poses. They may disclose the information in public court pro-
ceedings or in judicial decisions. Notwithstanding the foregoing,
information received by a Contracting State may be used for other
purposes when such information may be used for such other
purposes under the laws of both Contracting States and the
competent authority of the other Contracting State supplying the
information provides prior authorisation of such use.
(3) In no case shall the provisions of paragraphs 1 and 2 be
construed so as to impose on a Contracting State the obligation:
a) to carry out administrative measures at variance with the laws
and administrative practice of that or of the other Contracting
State;
b) to supply information which is not obtainable under the laws
or in the normal course of the administration of that or of the
other Contracting State;
c) to supply information which would disclose any trade, busi-
ness, industrial, commercial or professional secret or trade
process, or information the disclosure of which would be
contrary to public policy (ordre public).
(4) If information is requested by a Contracting State in accor-
dance with this Article, the other Contracting State shall use its
information gathering measures to obtain the requested informa-
tion, even though that other Contracting State may not need
such information for its own tax purposes. The obligation con-
tained in the preceding sentence is subject to the limitations of
paragraph 3 but in no case shall such limitations be construed
to permit a Contracting State to decline to supply information
solely because it has no domestic interest in such information.
(5) In no case shall the provisions of paragraph 3 be construed
to permit a Contracting State to decline to supply information
solely because the information is held by a bank, other financial
institution, nominee or person acting in an agency or a fiduciary
capacity or because it relates to ownership interests in a person.
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 25 | 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-25/
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