(1) Dividends paid by a company which is a resident of a
Contracting 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 re-
cipient is the beneficial owner of the dividends the tax so
charged shall not exceed 15 per cent of the gross amount of
the dividends.
This paragraph shall not affect the taxation of the company in
respect of the profits out of which the dividends are paid.
(3) The term “dividends” as used in this Article means in-
come from shares, and other income assimilated to income
from shares by the laws of the State of which the company
making the distribution is a resident, and income derived by a
“Stiller Gesellschafter” (sleeping partner) from his participa-
tion 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 Con-
tracting 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 per-
forms 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 establishment or fixed base. In such case the pro-
visions of Article 7 or Article 14, as the case may be, shall ap-
ply.
(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 divi-
dends paid by the company, except insofar as such dividends
are paid to a resident of that other State or insofar as the hold-
ing in the 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 undis-
'
tributed profits to a tax on the company’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-new-zealand-1980-base | BGBl. 1980 II S. 1222 | signed 1978-10-20 | published 1980-09-11 | Signed: 1978-10-20 | Gazette publication: 1980-09-11
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. Original pages20–22 retain an exchange of notes and a supplementary letter exchange. The German supplementary request on page21 is explicitly headed (Übersetzung) in print; OCR (Ubersetzung) is retained. The German editorial placeholders (Es folgt der Text der vorstehenden Note.) appear in BOTH printed columns and remain verbatim, not silently expanded or translated. Entry into force is unresolved in the retained audit; roster general application is not entry into force. Treaty preamble, closing, protocol, signatures, implementing law and any notes are retained separately at /review/de-new-zealand-1980-base/. Exact physical-page spans and unresolved OCR at /review/de-new-zealand-1980-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 1978-10-20; consent law 1980-09-04; gazette publication 1980-09-11. 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: 1978-01-01 (not a universal tax-specific rule). 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): Neuseeland R-P P: 31.03.2025 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. 1980 II S. 1222 | de-new-zealand-1980-base | de-new-zealand-1980-base | BGBl. 1980 II S. 1222 | signed 1978-10-20 | published 1980-09-11 | Signed: 1978-10-20 | Gazette publication: 1980-09-11 | Article 10 | en | Pending human wording, completeness, source authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-new-zealand-1980-base/en/articles/article-10/
Source, edition and limits
Source edition
de-new-zealand-1980-base | BGBl. 1980 II S. 1222 | signed 1978-10-20 | published 1980-09-11 | Signed: 1978-10-20 | Gazette publication: 1980-09-11
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. Original pages20–22 retain an exchange of notes and a supplementary letter exchange. The German supplementary request on page21 is explicitly headed (Übersetzung) in print; OCR (Ubersetzung) is retained. The German editorial placeholders (Es folgt der Text der vorstehenden Note.) appear in BOTH printed columns and remain verbatim, not silently expanded or translated. Entry into force is unresolved in the retained audit; roster general application is not entry into force. Treaty preamble, closing, protocol, signatures, implementing law and any notes are retained separately at /review/de-new-zealand-1980-base/. Exact physical-page spans and unresolved OCR at /review/de-new-zealand-1980-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 1978-10-20; consent law 1980-09-04; gazette publication 1980-09-11. 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: 1978-01-01 (not a universal tax-specific rule). 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): Neuseeland R-P P: 31.03.2025 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