1. Where:
a) an enterprise of a Contracting Party participates directly or
indirectly in the management, control or capital of an enter-
prise of the other Contracting Party, or
b) the same persons participate directly or indirectly in the man-
agement, control or capital of an enterprise of a Contracting
Party and an enterprise of the other Contracting Party,
and in either case conditions are made or imposed between the
two enterprises in their commercial or financial relations which
differ from those which would be made between independent
enterprises, then any profits which would, but for those con -
ditions, have accrued to one of the enterprises, but, by reason
of those conditions, have not so accrued, may be included in the
profits of that enterprise and taxed accordingly.
2. Where a Contracting Party intends to adjust the profits of
an enterprise in accordance with the principles set out in para-
graph 1, it shall inform the enterprise of the intended action in
good time and give it the opportunity to inform the other enter-
prise so as to give that other enterprise the opportunity to inform
in turn the other Contracting Party. However, the right of the
Contracting Party providing such information to make the
proposed adjustment shall not be thereby affected.
de-jersey-2015-base | BGBl. 2015 II S. 1326 | signed 2015-05-07 | published 2015-11-26 | Signed: 2015-05-07 | Gazette publication: 2015-11-26
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original consent law and limited-scope agreement, not consolidated/current law
Retrieved
2026-09-30
Text and language scope
Original limited-scope 2015 agreement on tax cooperation and certain items of income, not a comprehensive income/capital DBA. German and English named in the actual closing clause (PDF 6). Separate source-backed machine transcriptions, no full-language accuracy certification. No human review or current-law claim. Native coordinate-based machine transcription. Line breaks, hyphens, tight token gaps and superscripts retained without correction. Implementing law, titles, preambles, closing and signatures remain separate: /review/de-jersey-2015-base/. Source-page links refer to physical pages, not human-verified paragraph correspondence. Noindex is not access control.
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 2015-05-07; consent law 2015-11-20; gazette publication 2015-11-26 (BGBl. 2015 II S. 1326). These are not interchangeable dates. Article 10 states notification-based entry into force and application to specified taxes/proceedings from 29 August 2014; no resolved entry-into-force/current-applicability determination is made here. 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
This is the original limited-scope 2015 agreement, NOT a current consolidated text. No accompanying protocol is printed in this six-page publication. Article 9(7) refers to paragraph 2 of the protocol to the separate 4 July 2008 tax-information-exchange agreement; that instrument is NOT included or translated here. Article 11(3) links termination to that separate 2008 information-exchange agreement. The retained audit categorizes an earlier cooperation agreement as a predecessor, but that is not a finding that the separate information-exchange instrument was replaced. Later amendments/negotiations/MLI and current operation are unverified. 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. 1326 | de-jersey-2015-base | de-jersey-2015-base | BGBl. 2015 II S. 1326 | signed 2015-05-07 | published 2015-11-26 | Signed: 2015-05-07 | Gazette publication: 2015-11-26 | Article 8 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-jersey-2015-base/en/articles/article-8/
Source, edition and limits
Source edition
de-jersey-2015-base | BGBl. 2015 II S. 1326 | signed 2015-05-07 | published 2015-11-26 | Signed: 2015-05-07 | Gazette publication: 2015-11-26
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original consent law and limited-scope agreement, not consolidated/current law
Retrieved
2026-09-30
Text and language scope
Original limited-scope 2015 agreement on tax cooperation and certain items of income, not a comprehensive income/capital DBA. German and English named in the actual closing clause (PDF 6). Separate source-backed machine transcriptions, no full-language accuracy certification. No human review or current-law claim. Native coordinate-based machine transcription. Line breaks, hyphens, tight token gaps and superscripts retained without correction. Implementing law, titles, preambles, closing and signatures remain separate: /review/de-jersey-2015-base/. Source-page links refer to physical pages, not human-verified paragraph correspondence. Noindex is not access control.
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 2015-05-07; consent law 2015-11-20; gazette publication 2015-11-26 (BGBl. 2015 II S. 1326). These are not interchangeable dates. Article 10 states notification-based entry into force and application to specified taxes/proceedings from 29 August 2014; no resolved entry-into-force/current-applicability determination is made here. 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
This is the original limited-scope 2015 agreement, NOT a current consolidated text. No accompanying protocol is printed in this six-page publication. Article 9(7) refers to paragraph 2 of the protocol to the separate 4 July 2008 tax-information-exchange agreement; that instrument is NOT included or translated here. Article 11(3) links termination to that separate 2008 information-exchange agreement. The retained audit categorizes an earlier cooperation agreement as a predecessor, but that is not a finding that the separate information-exchange instrument was replaced. Later amendments/negotiations/MLI and current operation are unverified. 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