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 State.
2. However, such dividends may also be taxed in the Con-
tracting State of which the company paying the dividends is a
resident and according to the laws of that State, but if the bene-
ficial owner of the dividends is a resident of the other Contracting
State the tax so charged shall not exceed:
(a) 5 per cent of the gross amount of the dividends if the bene-
ficial owner (other than an individual or a partnership) holds
directly at least 10 per cent of the capital of the company pay-
ing the dividends;
(b) 15 per cent of the gross amount of the dividends in all other
cases.
As long as a resident in the Federal Republic of Germany is en-
titled under German law to a tax credit (Anrechnung der Koerper-
schaftsteuer) in respect of dividends paid by a company that is a
resident of the Federal Republic of Germany, the beneficial
owner of the dividends subject to sub-paragraph b) shall be en-
titled to a further relief of tax of 5 per cent of the gross amount of
the dividends.
3. The term “dividends” as used in this Article means:
(a) dividends on shares including income from shares, “jouis-
sance” shares or “jouissance” rights, mining shares,
founders’ shares or other rights, not being debt-claims, par-
ticipating in profits, and
(b) other income which is subjected to the same taxation treat-
ment as income from shares by the laws of the State of which
the company making the distribution is a resident, and for the
purpose of taxation in the Federal Republic of Germany,
income derived by a sleeping partner from his participation as
such and distributions on certificates of an investment trust.
4. The provisions of paragraphs 1 and 2 shall not apply if the
beneficial owner of the dividends, being a resident of a Contract-
ing 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, or performs in that
other State independent personal services from a fixed base
situated therein and the holding in respect of which the dividends
are paid is effectively connected with such permanent establish-
ment or fixed base. In such case the provisions of Article 7 or
Article 14, as the case may be, shall apply.
5. Where a company which is a resident of a Contracting 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, except insofar as such dividends are paid to a resident
of that other State or insofar as the holding in respect of which
the dividends are paid is effectively connected with a permanent
establishment or a fixed base situated in that other State, nor
subject the company’s undistributed profits to a tax on the com-
pany’s undistributed profits, even if the dividends paid or the
undistributed profits consist wholly or partly of profits or income
arising in such other State.
de-kuwait-2000-base | BGBl. 2000 II S. 390 | signed 1999-05-18 | published 2000-03-09 | Signed: 1999-05-18 | Gazette publication: 2000-03-09
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 Arabic 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-kuwait-2000-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 1999-05-18; consent law 2000-02-27; gazette publication 2000-03-09. 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: 1998-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 14. Juli 1989, 2. August 2000. 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. This signed 1999-05-18 source replaces earlier convention signed 1987-12-04; exact cessation and transition require the entry article, not an edition-year inference. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Kuwait R-P P: 08.05.2025 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. 2000 II S. 390 | de-kuwait-2000-base | de-kuwait-2000-base | BGBl. 2000 II S. 390 | signed 1999-05-18 | published 2000-03-09 | Signed: 1999-05-18 | Gazette publication: 2000-03-09 | Article 10 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-kuwait-2000-base/en/articles/article-10/
Source, edition and limits
Source edition
de-kuwait-2000-base | BGBl. 2000 II S. 390 | signed 1999-05-18 | published 2000-03-09 | Signed: 1999-05-18 | Gazette publication: 2000-03-09
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 Arabic 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-kuwait-2000-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 1999-05-18; consent law 2000-02-27; gazette publication 2000-03-09. 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: 1998-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 14. Juli 1989, 2. August 2000. 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. This signed 1999-05-18 source replaces earlier convention signed 1987-12-04; exact cessation and transition require the entry article, not an edition-year inference. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Kuwait R-P P: 08.05.2025 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