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Germany – Mauritius · Source editionArticle 23 Elimination of Double Taxation

Unreviewed · applicability unverified

Double taxation shall be eliminated as follows:

PDF page · 13

(1)

(1) In the case of Mauritius: (a) Where a resident of Mauritius derives income from the Feder- al Republic of Germany the amount of tax on that income payable in the Federal Republic of Germany in accordance with the provisions of this Agreement may be credited against the Mauritius tax imposed on that resident, (b) Where a company which is a resident of the Federal Repub- lic of Germany pays a dividend to a resident of Mauritius who controls, directly or indirectly, at least 5 % of the capital of the company paying the dividend, the credit shall take into account (in addition to any German tax for which credit may be allowed under the provisions of subparagraph (a) of this paragraph) the German tax payable by the first-mentioned company in respect of the profits out of which such dividend is paid, provided that any credit allowed under sub paragraphs (a) and (b) shall not exceed the Mauritius tax (as computed before allowing any such credit), which is appropriate to the profits or income derived from sources within the Federal Republic of Germany.

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(2)

(2) In the case of the Federal Republic of Germany: (a) Subject to the provisions of German tax law regarding credit for foreign tax, there shall be allowed as a credit against German tax payable in respect of income which, according to this Agreement, may be taxed in Mauritius, the Mauritius tax paid under the laws of Mauritius and in accordance with this Agreement. (b) Where in accordance with any provisions of the Agreement, income derived by a resident of the Federal Republic of Germany is exempt from tax in the Federal Republic of Germany, the Federal Republic of Germany may neverthe- less in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.

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Source, edition and limits
Source edition
de-mauritius-2012-base | BGBl. 2012 II S. 1050 | Signed: 2011-10-07 | Gazette publication: 2012-10-09
Source form
official-publication PDF retained unchanged; reader derives from an evidenced native font-map encoding-recovery derivative, not OCR
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
The signing clause identifies German and English as equally authentic; both are supplied as separate machine transcriptions. No additional authentic language is identified in that clause. 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-mauritius-2012-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2011-10-07; consent law 2012-10-02; Gazette publication 2012-10-09; treaty entry into force 2012-12-07 (retained official-article audit evidence); general tax application from 2013-01-01 (BMF 2026 roster, not every tax-specific transition). Consent-law commencement 2012-10-10 is NOT treaty entry into force. Encoding-recovery method: only the source font code00 /space Unicode mapping U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyph, 278-unit advance, unchanged page content streams and 23/23 identical source/derivative page renders for this edition evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No model-generated treaty wording and no OCR.
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. BASE EDITION WITH KNOWN LATER AMENDMENT OMITTED. The 2021-10-29 amendment is not incorporated; its exact entry date remains unresolved. No current-law clearance. 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 integral protocol signed 7 October 2011 is retained separately. A LATER AMENDING PROTOCOL signed 29 October 2021 is NOT included or consolidated here. The 2026 roster records general application from 1 January 2023 and cites the entry notice BGBl. 2023 II No.50; the official article still displays ./. for protocol entry into force. Exact amendment entry date and tax-specific effect remain UNRESOLVED pending examination of that notice. Do not treat this base edition as current consolidated law. MLI and any other later changes are not exhaustively verified. 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): amending-protocol; signature date: 2021-10-29; general application from: 2023-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2012 II S. 1050
SHA-256
bd5b5aff9b41c4b21c0c62bc2e2b3ba2798236a1e1e886dec8f45ae3680426a4

Citation

Copyable citation

BGBl. 2012 II S. 1050 | de-mauritius-2012-base | de-mauritius-2012-base | BGBl. 2012 II S. 1050 | Signed: 2011-10-07 | Gazette publication: 2012-10-09 | Article 23 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-mauritius-2012-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. 2012 II S. 1050

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

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