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Germany – New Zealand · Source editionArticle 11 Interest

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(1)

(1) Interest arising in a Contracting State and paid to a re- sident of the other Contracting State may be taxed in that other State.

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(2)

(2) However, such interest may also be taxed in the Con- tracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the in- terest the tax so charged shall not exceed 10 per cent of the gross amount of the interest. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation.

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(3)

(3) Notwithstanding the provisions of paragraph 2, a) interest arising in the Federal Republic of Germany and paid to the New Zealand Government shall be exempt from German tax; b) interest arising in New Zealand and paid to the German Government, the Deutsche Bundesbank, the Kreditanstalt für Wiederaufbau or the Deutsche Gesellschaft für wirt- schaftliche Zusammenarbeit (Entwicklungsgesellschaft) shall be exempt from New Zealand tax.

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(4)

(4) The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor’s profits, and in particular, income from government securities and income from bonds or debentures, including premiums attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as in- terest for the purpose of this Article. However, the term “inter- est” does not include income dealt with in Article 10.

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(5)

(5) The provisions of paragraphs 1 to 3 shall not apply if the beneficial owner of the interest, being a resident of a Contract- ing State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Articie 14, as the case may be, shall apply.

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(6)

(6) Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a “Land’’, a political sub- division, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resi- dent of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was in- curred, and such interest is borne by such permanent estab- lishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.

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(7)

(7) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the pro- visions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall re- main taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

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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
Citation
BGBl. 1980 II S. 1222
SHA-256
764a6042bb203b0ae49667d3ab9c0fdd717fdd419f4e1876372edc40f6723686

Citation

Copyable citation

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 11 | 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-11/

Disclaimers

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

BGBl. 1980 II S. 1222

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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