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Germany – Thailand · Source editionArticle 1

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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 be taxed in the Con tracting State in which it arises, and according to the law of that State, but the tax so charged shall not ex- ceed 25 per cent of the gross amount of the interest

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(3)

(3) Notwithstanding the provisions of paragraph 2, the tax of a Contracting State on interest received by any financial institution (including an insurance company) which is a company of the other Contracting State shall not exceed 10 per cent of the gross amount of the in- terest, if the enterprise paying the interest engages in an industrial undertaking within the meaning of para- graph 4, subparagraph b, of Article 10.

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(4)

(4) Notwithstanding the provisions of paragraphs 2 and 3, interest arising in a Contracting State shall be exempt from tax in that State if the interest is received by a) the other Contracting State, a ‘Land*, a political subdivision, a local authority or a local administra- tion thereof, or b) any financial institution wholly owned by the other Contracting State, a "Land", a political subdivision, @ local authority or a local administration thereof, and in particular, in the case of the Federal Repub- lic, by the "Deutsche Bundesbank” or the “Kredi anstalt für Wiederaufbau”, and in the case of Thai- land, by the “Bank of Thailand“, or ©) by a resident of the other Contracting State on bonds issued by the Government of the first-mentioned State.

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(5)

(6) The term "interest" as used in this Article means income from Government securities, bonds or debentures, whether or not secured by mortgage and whether or not carrying a right to participate in profits, and debt-claims of every kind as well as all other income assimilated to income from money lent by the taxation law of the State in which the income arises.

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(6)

(6) The provisions of paragraphs 1 10 4 shall not ap- ply if the recipient of the interest, being a resident of a Contracting State, has in the other Contracting State in which the interest arises a permanent establishment with which the debt-claim from which the interest arises is effectively connected, provided that under the law of that other State the interest is taxed as part of the profits of the permanent establishment.

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(7)

(9) Interest shall be deemed to arise in a Contracting State when the payer is that State, 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 Contracting State or not, has in a Contracting State a permanent establishment’ in con- nection with which the indebtedness on which the in- terest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment is situated.

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(8)

(8) Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the interest paid, 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Agree- ment.

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Source, edition and limits
Source edition
de-thailand-1968-base | BGBl. 1968 II S. 589 | signed 1967-07-10 | published 1968-07-26 | Signed: 1967-07-10 | Gazette publication: 1968-07-26
Source form
retained original official-publication scan; reader uses a separately retained unreviewed OCR derivative
Source scope
original implementing law, DE/EN/Thai base treaty and accompanying exchange of notes; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
ORIGINAL EDITION, unreviewed OCR. Authentic treaty languages: German (de), English (en), Thai (th). Distinct DE/EN assets use separate left/right physical columns on even PDF pages2–32. Thai original text IS PRESENT on alternating odd PDF pages3–33, but retained OCR is unusable for Thai: no Thai machine reader is supplied. Missing usable authentic-language asset: th; no full-language claim. German exchange-of-notes text is labelled Übersetzung in the original. All OCR defects, damaged numerals, uncertain punctuation and line-end hyphens are retained. Source-observed article/paragraph IDs do not replace the visibly erroneous OCR wording. Unreviewed coordinate-based machine transcription of this original source edition only. OCR words are unchanged; rows reconstructed by word coordinates. Known misspellings and damaged numerals remain visible. Source-observed structural paragraph IDs may differ from erroneous OCR numerals. This is not exact legal transcription. Treaty preamble, closing formula, exchange of notes and signatures are separate retained assets, not part of the last article. Full supplements: /review/de-thailand-1968-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. Signature: 1967-07-10; consent law: 1968-07-19; gazette publication: 1968-07-26. Edition ID year is the retained publication label, NOT the signature year. Treaty entry into force (retained audit/cached article): 1968-12-04. Roster general application: 1967-01-01; NOT a universal tax-specific rule and NOT the entry date. Cached article entry statements (possibly about multiple instruments): ['4. Dezember 1968']. None means unresolved, not no legal effect. All dates retain their evidence scope; no fresh current-law verification. 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 printed accompanying exchange of notes is retained separately from treaty articles; German note text is marked Übersetzung in the Thailand original. Retained edition-audit relationships: []. MLI effects, later protocols, replacements, suspensions, complete amendment chain and current applicability have NOT been verified or incorporated. No current-law claim. 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
Citation
BGBl. 1968 II S. 589
SHA-256
8a0e863c203f731b138220878bf7b1edec742b93bafba075bfb4ab7146b8c627

Citation

Copyable citation

BGBl. 1968 II S. 589 | de-thailand-1968-base | de-thailand-1968-base | BGBl. 1968 II S. 589 | signed 1967-07-10 | published 1968-07-26 | Signed: 1967-07-10 | Gazette publication: 1968-07-26 | Article 11 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-thailand-1968-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. 1968 II S. 589

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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