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Germany – Liberia · Source editionArticle 23 Relief from double taxation

Unreviewed · applicability unverified

(1)

(1) Tax shall be determined in the case of a resident of the Federal Republic of Germany as follows: a) Unless the provisions of sub-paragraph b) apply. there shall be excluded from the basis upon which German tax is imposed, any item of income derived from Liberia and any item of capital situated within Liberia, which, according to this Agreement, may be taxed in Liberia. The Federal Republic of Germany, however, retains the right to take into account in the determina- tion of its rate of tax the items of income and capital so excluded. In the case of income from dividends, the foregoing provisions of this sub-paragraph shall apply only to such dividends as are paid to a company being a resident of the Federal Republic of Germany by a company being a resident of Liberia if at least 25 per cent of the capital of the Liberian company is held directly by the German company. There shall also be excluded from the basis upon which German tax is imposed any shareholding, the dividends of which, if paid, would be excluded from the basis upon which tax is imposed according to the immedia- tely foregoing sentence. b Subject to the provisions of German tax law regard- ing credit for foreign tax, there shall be allowed as a credit against German income tax and corporation tax, including the surcharge thereon, payable in respect of the following items of income derived from Liberia, the Liberian tax paid under the laws of Liberia and in accordance with this Agreement on aa) dividends to which sub-paragraph a) does not apply; provided that in the case of dividends to which paragraph (2), sub-paragraph a), of Ar- ticle 10 applies, the amount so credited shall be 15 per cent of the gross amount of such dividends; bb) interest to which paragraph (2) of Article 11 applies; cc) royalties to which paragraph (2) of Article 12 applies; dd) gains to which paragraph (3) of Article 13 applies; ee) remuneration to which Article 16 applies. The credit shall not, however, exceed that part of the German tax, as computed before the credit is given, which is appropriate to such items of income. For purposes of credit referred to in the foregoing sub-paragraph b), where the rate of Liberian tax on interest, or on royalties to which paragraph (2), sub-paragrap:ı b), of Article 12 applies, is reduced below 10 per cent of the gross amount of such in- terest or royalties by virtue of special incentive measures designed to promote economic development in Liberia, the amount of Liberian tax shall be deemed to be 10 per cent of the gross amount of suh interest or royalties.

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(2)

(2) Tax shall be determined in the case of a resident of Liberia as follows: a) Unless the provisions of sub-paragraph b) apply, there shall be excluded from the basis upon which Liberian tax is imposed, any item of income derived from the Federal Republic of Germany and any item of capital situated within the Federal Republic of Germany, which, according to this Agreement, may be taxed in the Federal Republic of Germany. Liberia, however, retains the right to take into account in the determination of its rate of tax the items of income and capital so excluded. Subject to the provisions of Liberian tax law regard- b ing credit for foreign tax, there shall be allowed as a credit against Liberian income tax payable in respect of the following items of income derived from the Federal Republic of Germany, the German tax paid under the laws of the Federal Republic of Ger- many and in accordance with this Agreement on aa) dividends to which paragraph (2) of Article 10 applies; bb) interest to which paragraph (2) of Article f1 applies; cc) royalties to which paragraph (2) of Article 12 applies; dd) gains to which paragraph (3) of Article 13 applies; ee) remuneration to which Article 16 applies. The credit shall not, however, exceed that part of the Liberian tax, as computed before the credit is given, which is appropriate to such items of income.

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Source, edition and limits
Source edition
de-liberia-1973-base | BGBl. 1973 II S. 1285 | signed 1970-11-25 | published 1973-09-06 | Signed: 1970-11-25 | Gazette publication: 1973-09-06
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-liberia-1973-base/. Exact physical-page spans and unresolved OCR at /review/de-liberia-1973-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 1970-11-25; consent law 1973-08-30; gazette publication 1973-09-06. Edition ID year is not a signature date. Treaty entry into force: 1974-04-25. Roster general application: 1970-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 25. April 1974. 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. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Liberia R-A V. 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
Citation
BGBl. 1973 II S. 1285
SHA-256
7f11bb820fbc626637ca673b6bef95b9a87d275112fdd54dfbcafefb74b1b584

Citation

Copyable citation

BGBl. 1973 II S. 1285 | de-liberia-1973-base | de-liberia-1973-base | BGBl. 1973 II S. 1285 | signed 1970-11-25 | published 1973-09-06 | Signed: 1970-11-25 | Gazette publication: 1973-09-06 | Article 23 | en | Pending human wording, completeness, source authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-liberia-1973-base/en/articles/article-23/

Disclaimers

Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.

BGBl. 1973 II S. 1285

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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