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Germany – North Macedonia · Source editionArticle 7 Business Profits

Unreviewed · applicability unverified
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(1)

(1) The profits of an enterprise of a Contracting Party shall be taxable only in the sovereign territory of that Contracting Party unless the enterprise carries on business in the sovereign territory of the other Contracting Party through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the sovereign territory of the other Contracting Party but only so much of them as is attributable to that permanent establishment.

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(2)

(2) Subject to the provisions of paragraph 3, where an enterprise of a Contracting Party carries on business in the sovereign territory of the other Contracting Party through a permanent establishment situated therein, there shall in the sovereign territory of each Contracting Party be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.

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(3)

(3) In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the sovereign territory of the Contracting Party in which the permanent establishment is situated or elsewhere.

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(4)

(4) Insofar as it has been customary in the sovereign territory of a Contracting Party to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting Party from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.

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(5)

(5) No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.

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(6)

(6) For the purposes of the preceding paragraphs of this Article, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.

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(7)

(7) Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

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Source, edition and limits
Source edition
de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Macedonian as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. 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-north-macedonia-2010-base/. PDF page links identify pages, not verified paragraph correspondence.
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 2006-07-13; consent law 2010-10-16; gazette publication 2010-10-22. 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: 2011-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 29.11.2010, 16.01.2018. 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. Later amending protocol signed 2016-11-14, entered into force 2018-01-16, general application 2019-01-01; NOT included in this base source. Tax-specific application needs review. Source implementing law expressly publishes the treaty in the corrected version resulting from the exchange of notes dated 2008-07-23. Those corrections are incorporated by the official publication, not by this reader. The separately headed exchange-of-notes document is not printed in this retained PDF; do not mistake the law reference for a complete separate notes reader. 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. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2016-11-14; entry into force: 2018-01-16; general application from: 2019-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2010 II S. 1153
SHA-256
43e6d898031ca8d24d27d7afba7dd86c63d7eaa33b7d8b9cd195d0c1e3c5122d

Citation

Copyable citation

BGBl. 2010 II S. 1153 | de-north-macedonia-2010-base | de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22 | Article 7 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-north-macedonia-2010-base/en/articles/article-7/

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

BGBl. 2010 II S. 1153

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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