(1) The competent authorities of the Contracting States shall
exchange such information as is forseeably relevant for carrying
out the provisions of this Agreement or to the administration or
enforcement of the domestic laws concerning taxes of every kind
and description imposed on behalf of a Contracting State, of a
Land, or a political subdivision or local authority thereof, insofar
as the taxation thereunder is not contrary to this Agreement. The
exchange of information is not restricted by Articles 1 and 2.
(2) Any information received under paragraph 1 by a Contract-
ing State shall be treated as secret in the same manner as infor-
mation obtained under the domestic laws of that State and shall
be disclosed only to persons or authorities (including courts and
administrative bodies) concerned with the assessment or collec-
tion of, the enforcement or prosecution in respect of, or the
determination of appeals in relation to the taxes referred to in
paragraph 1 or the oversight of the above. Such persons or au-
thorities shall use the information only for such purposes. They
may disclose the information in public court proceedings or in
judicial decisions.
(3) In no case shall the provisions of paragraphs 1 and 2 be
construed so as to impose on a Contracting State the obligation:
(a) to carry out administrative measures for the supply of infor-
mation at variance with the laws and administrative practice
of that or of the other Contracting State;
(b) to supply information which is not obtainable under the laws
or in the normal course of the administration of that or of the
other Contracting State;
(c) to supply information which would disclose any trade, busi-
ness, industrial, commercial or professional secret or trade
process, or information, the disclosure of which would be
contrary to public policy (ordre public).
(4) If information is requested by a Contracting State in accor-
dance with this Article, the other Contracting State shall use its
information gathering measures to obtain the requested informa-
tion, even though that other State may not need such information
for its own tax purposes. The obligation contained in the preced-
ing sentence is subject to the limitations of paragraph 3 but in no
case shall such limitations be construed to permit a Contracting
State to decline to supply information solely because it has no
domestic tax interest in such information.
(5) In no case shall the provisions of paragraph 3 be construed
to permit a Contracting State to decline to supply information
solely because the information is held by a bank, other financial
institution, nominee or person acting in an agency or a fiduciary
capacity or because it relates to ownership interests in a person.
de-philippines-2014-base | BGBl. 2014 II S. 822 | Signed: 2013-09-09 | Gazette publication: 2014-10-31
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-philippines-2014-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2013-09-09; consent law 2014-10-27; Gazette publication 2014-10-31; treaty entry into force 2015-12-18 (retained official-article audit evidence); general tax application from 2016-01-01 (BMF 2026 roster, not every tax-specific transition). Consent-law commencement 2014-11-01 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. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. 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 2013 agreement replaces the 1983-07-22 agreement; retained official-article audit reports predecessor cessation 2015-12-17. Article32 transitional tax rules are retained, not simplified into one universal date. The accompanying protocol is separate. Later amendments, MLI and present applicability 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.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2014 II S. 822 | de-philippines-2014-base | de-philippines-2014-base | BGBl. 2014 II S. 822 | Signed: 2013-09-09 | Gazette publication: 2014-10-31 | Article 27 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-philippines-2014-base/en/articles/article-27/
Source, edition and limits
Source edition
de-philippines-2014-base | BGBl. 2014 II S. 822 | Signed: 2013-09-09 | Gazette publication: 2014-10-31
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-philippines-2014-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2013-09-09; consent law 2014-10-27; Gazette publication 2014-10-31; treaty entry into force 2015-12-18 (retained official-article audit evidence); general tax application from 2016-01-01 (BMF 2026 roster, not every tax-specific transition). Consent-law commencement 2014-11-01 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. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. 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 2013 agreement replaces the 1983-07-22 agreement; retained official-article audit reports predecessor cessation 2015-12-17. Article32 transitional tax rules are retained, not simplified into one universal date. The accompanying protocol is separate. Later amendments, MLI and present applicability 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.
Text language and status
en · authentic-language-transcription · machine-transcription