(1) In this Agreement, unless the context otherwise requires:
(a) the term “Mauritius” means the Republic of Mauritius and
includes:
(i) all the territories and islands which, in accordance with
the laws of Mauritius, constitute the State of Mauritius;
(ii) the territorial sea of Mauritius; and
(iii) any area outside the territorial sea of Mauritius which in
accordance with international law has been or may here-
after be designated, under the laws of Mauritius, as an
area, including the Continental Shelf, within which the
sovereign rights of Mauritius with respect to the sea, the
sea-bed and sub-soil and their natural resources may be
exercised;
(b) the term “Federal Republic of Germany” means the territory
of the Federal Republic of Germany, as well as the area of the
sea-bed, its subsoil and the superjacent water column adja-
cent to the territorial sea, insofar as the Federal Republic of
Germany exercises therein sovereign rights and jurisdiction
in conformity with international law and its national legisla-
tion for the purpose of exploring, exploiting, conserving and
managing the living and non-living natural resources;
(c) the terms “a Contracting State” and “the other Contracting
State” mean the Federal Republic of Germany or Mauritius,
as the context requires;
(d) the term “person” includes an individual, a company, a trust
and any other body of persons;
(e) the term “company” means any body corporate or any enti-
ty which is treated as a body corporate for tax purposes;
(f) the term “enterprise” applies to the carrying on of any
business;
(g) the term “business” includes the performance of profession-
al services and of other activities of an independent charac-
ter;
(h) the terms “enterprise of a Contracting State” and “enterprise
of the other Contracting State” mean respectively an enter-
prise carried on by a resident of a Contracting State and an
enterprise carried on by a resident of the other Contracting
State;
(i) the term “international traffic” means any transport by a ship
or aircraft operated by an enterprise that has its place of ef-
fective management in a Contracting State, except when the
ship or aircraft is operated solely between places in the oth-
er Contracting State;
(j) the term “national” means
(i) in respect of the Federal Republic of Germany:
any German within the meaning of the Basic Law for the
Federal Republic of Germany and any legal person, part-
nership and association deriving its status as such from
the laws in force in the Federal Republic of Germany;
(ii) in respect of Mauritius:
any individual having the citizenship of Mauritius and any
legal person, partnership (société) or association deriving
its status as such from the laws in force in Mauritius;
(k) the term “competent authority” means:
(i) in the case of Mauritius, the Minister to whom the respon-
sibility for the subject of finance is assigned or his autho-
rised representative;
(ii) in the case of the Federal Republic of Germany, the
Federal Ministry of Finance or the agency to which it has
delegated its powers;
(l) the term “tax” means German tax or Mauritius tax, as the
context requires.
(2) As regards the application of the Agreement at any time by
a Contracting State, any term not defined therein shall, unless
the context otherwise requires, have the meaning that it has at
that time under the law of that State for the purposes of the tax-
es to which the Agreement applies, any meaning under the appli-
cable tax laws of that State prevailing over a meaning given to
the term under other laws of that State.
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
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 3 | 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-3/
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