(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 ben-
eficial owner of the dividends is a resident of the other Contract-
ing State, the tax so charged shall not exceed:
a) 5 per cent of the gross amount of the dividends if the
beneficial owner (other than an individual or a partnership)
holds directly at least 10 per cent of the capital of the
company paying the dividends;
b) 15 per cent of the gross amount of the dividends in all other
cases.
This paragraph shall not affect the taxation of the company in
respect of the profits out of which the dividends are paid.
(3) Notwithstanding the provisions of paragraphs 1 and 2
above, in the Federal Republic of Germany, income of a
sleeping partner (“stiller Gesellschafter”) from his participation
as such or from a “partiarisches Darlehen” or a “Gewinnobliga-
tion” that is deductible in determining the profits of the debtor
may be taxed in the Federal Republic of Germany according to
its laws.
(4) As long as Singapore does not impose a tax on dividends
in addition to the tax chargeable on the profits or income of a
company, dividends paid by a company which is a resident of
Singapore to a resident of the Federal Republic of Germany
shall be exempt from any tax in Singapore which may be
chargeable on dividends in addition to the tax chargeable on
the profits or income of the company. Under the full imputation
system currently adopted in Singapore, the tax deductible from
dividends is a tax on the profits or income of the company and
not a tax on dividends within the meaning of this Article. If sub-
sequent to the signing of the Agreement, Singapore imposes a
tax on dividends in addition to the tax chargeable in respect of
the profits or income of a company which is a resident of Singa-
pore, such tax may be charged but the tax so charged on the
dividends derived by a resident of the Federal Republic of Ger-
many who is the beneficial owner of such dividends shall be in
accordance with the provisions of paragraph 2.
(5) The term “dividends” as used in this Article means
income from shares, “jouissance” shares or “jouissance” rights,
mining shares, founders’ shares or other income which is sub-
jected to the same taxation treatment as income from shares by
the laws of the State of which the company making the distribu-
tion is a resident and includes distributions of an investment
fund or investment trust. In the Federal Republic of Germany,
the term “dividends” includes also income derived by a sleep-
ing partner (“stiller Gesellschafter”) from his participation as
such or from a “partiarisches Darlehen” or a “Gewinnobliga-
tion”.
(6) The provisions of paragraphs 1 and 2 above shall not
apply if the beneficial owner of the dividends, being a resident
of a Contracting State, carries on business in the other Con-
tracting State of which the company paying the dividends is a
resident, through a permanent establishment situated therein,
or performs 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 apply.
(7) 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 dividends
paid by the company, except insofar as such dividends are paid
to a resident of that other State or insofar as the holding in
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 undistributed profits to
a tax on the company’s undistributed profits, even if the divi-
dends paid or the undistributed profits consist wholly or partly
of profits or income arising in such other State.
de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03
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
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-singapore-2006-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. 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. Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2019-12-09; citation: BGBl. 2020 II S. 1178; BGBl. 2021 II S. 437; entry into force: 2021-03-29; general application: 2022-01-01 / domestic-notification-ordinance; citation: BGBl. 2021 I S. 5218; entry into force: 2021-12-23
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2006 II S. 930 | de-singapore-2006-base | de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03 | Article 10 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-singapore-2006-base/en/articles/article-10/
Source, edition and limits
Source edition
de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03
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
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-singapore-2006-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. 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. Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2019-12-09; citation: BGBl. 2020 II S. 1178; BGBl. 2021 II S. 437; entry into force: 2021-03-29; general application: 2022-01-01 / domestic-notification-ordinance; citation: BGBl. 2021 I S. 5218; entry into force: 2021-12-23
Text language and status
en · authentic-language-transcription · machine-transcription