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Germany – Slovenia · Source editionArticle 11 Interest

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(1)

(1) Interest arising in a Contracting State and paid to a resident 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 Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the interest.

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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 Government of the Republic of Slovenia, the Bank of Slovenia or the Slovenian Export Corporation and interest paid in consideration of a loan guaranteed by the Slovenian Export Corporation and interest paid in consideration of a loan guaranteed by the Republic of Slovenia in respect of export or foreign direct investment shall be exempt from German tax; b) interest arising in the Republic of Slovenia and paid to the Government of the Federal Republic of Germany, the Deut- sche Bundesbank, the Kreditanstalt für Wiederaufbau or the Deutsche Investitions- und Entwicklungsgesellschaft (DEG) and interest paid in consideration of a loan guaranteed by the Federal Republic of Germany in respect of export or foreign direct investment shall be exempt from Slovenian 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 mort- gage, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penal- ty charges for late payment shall not be regarded as interest for the purpose of this Article.

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(5)

(5) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a Contracting 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 ser- vices 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 Article 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 subdivision, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contract- ing State or not, has in a Contracting State a permanent estab- lishment or a fixed base in connection with which the indebt- edness on which the interest is paid was incurred, and such interest is borne by such permanent establishment 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 provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain 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-slovenia-2006-base | BGBl. 2006 II S. 1091 | signed 2006-05-03 | published 2006-12-07 | Signed: 2006-05-03 | Gazette publication: 2006-12-07
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 Slovenian 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-slovenia-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 as current law. Signed 2006-05-03; consent law 2006-12-02; gazette publication 2006-12-07. 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: 2007-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 19. Dezember 2006, 30. Juli 2012. 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 2011-05-17, entered into force 2012-07-30, general application 2012-07-30; NOT included in this base source. Tax-specific application needs review. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Slowenien R-P P: 18.03.2024 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. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2011-05-17; entry into force: 2012-07-30; general application from: 2012-07-30; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2006 II S. 1091
SHA-256
7c31fb7a3bb26cdc29af29f1edf7c8dcbb6f9d808599f7f25b7fd2a221d00454

Citation

Copyable citation

BGBl. 2006 II S. 1091 | de-slovenia-2006-base | de-slovenia-2006-base | BGBl. 2006 II S. 1091 | signed 2006-05-03 | published 2006-12-07 | Signed: 2006-05-03 | Gazette publication: 2006-12-07 | Article 11 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-slovenia-2006-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. 2006 II S. 1091

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

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