(1) For the purposes of this Agreement, unless the context
otherwise requires:
(a) the term “Philippines” means the Republic of the Philippines,
and when used in a geographical sense means the archipel-
agic territory comprising the Republic of the Philippines as
defined in its Constitution and laws, including adjacent areas
and such other areas in the sea and in the air within which
the Philippines has sovereignty, jurisdiction or similar rights
under international law;
(b) the term “Federal Republic of Germany” means the Federal
Republic of Germany, and when used in a geographical
sense means the territory of the Federal Republic of Germany
as well as the area of the sea-bed, its sub-soil and the super-
jacent water column adjacent to the territorial sea, insofar as
Germany may exercise sovereign rights and jurisdiction in
conformity with international law and its national legislation
for the purpose of exploring, exploiting, conserving and man-
aging the living and non-living natural resources or for the
production of energy from renewable sources;
(c) the terms “a Contracting State” and “the other Contracting
State” mean the Federal Republic of Germany or the Philip-
pines as the context requires;
(d) the term “person” includes an individual, an estate, a trust, a
company 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 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 or an en-
terprise carried on by a resident of the other Contracting
State;
(g) the term “international traffic” means any transport by a ship
or aircraft operated by an enterprise of a Contracting State,
except when the ship or aircraft is operated solely between
places in the other Contracting State;
(h) the term “national” means:
(i) in respect of the Republic of the Philippines
any individual possessing the nationality of the Philip-
pines, and any legal person, partnership or association
deriving its status as such from the laws in force in the
Philippines;
(ii) 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;
(i) the term “competent authority” means:
(i) in the case of the Philippines, the Secretary of
Finance or his/her authorized representative;
(ii) in the case of the Federal Republic of Germany the Fed-
eral Ministry of Finance or the agency to which it has del-
egated its powers.
(2) As regards the application of this 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 this Agreement applies, any meaning under the ap-
plicable tax laws of that State prevailing over a meaning given to
the term under other laws of that State.
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 3 | 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-3/
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