(1) Les bénéfices provenant de l’exploitation, en trafic inter-
national, de navires ou d’aéronefs ne sont imposables que dans
l’État contractant où le siège de direction effective de l’entreprise
est situé.
(2) Au sens du présent article, l’expression «bénéfices prove-
nant de l’exploitation, en trafic international, de navires ou d’aé-
ronefs» comprend également les bénéfices provenant:
a) de la location coque nue occasionnelle de navires ou d’aé-
ronefs et
b) de l’usage ou de la location de conteneurs (y compris les
trailers et équipements servant au transport des conteneurs),
lorsque ces activités relèvent de l’exploitation de navires ou d’aé-
ronefs en trafic international.
(3) Si le siège de direction effective d’une entreprise de navi-
gation maritime est à bord d’un navire, ce siège est considéré
comme situé dans l’État contractant où se trouve le port d’at-
tache de ce navire ou, à défaut de port d’attache, dans l’État
contractant dont l’exploitant du navire est un résident.
(4) Les dispositions du paragraphe 1 s’appliquent aussi aux
bénéfices provenant de la participation à un pool, une exploita-
tion en commun ou un organisme international d’exploitation.
de-tunisia-2018-base | BGBl. 2018 II S. 710 (consent law); S. 711–735 (convention and protocol) | signed 2018-02-08 | published 2018-12-28 | Signed: 2018-02-08 | Gazette publication: 2018-12-28
Source form
Official original-publication PDF with native text layer; machine reader is not the facsimile
Source scope
Consent law, German/French replacement convention and integral protocol; not consolidated current law
Retrieved
2026-10-01
Text and language scope
Unreviewed machine transcription. Original 2018 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, public indexing or deployment approval. Preview only; noindex is not access control. The new 26-page source contains German and French. Both are transcribed from this 2018 PDF only. Closing page 21 declares German, Arabic and French authentic; French prevails in divergent German/Arabic interpretation. Arabic is linked separately by BMF but was NOT fetched or parsed. No complete authentic-language-set claim, English text or translation. Native spans, line breaks and hyphens are retained without wording correction; recorded coordinate-based word gaps separate adjacent native spans. Complete law, preamble, closing, protocol, shared signatures and running notices: /review/de-tunisia-2018-base/.
Review status
Pending independent qualified human wording, completeness, currentness, alignment and rendering review. No human approvals.
Currentness
Original source edition; not a verified current-law consolidation. Signed 2018-02-08; consent law 2018-12-11; gazette publication 2018-12-28. Treaty entry 2019-12-16, not application. Roster general application 2020-01-01 is not a universal tax-specific rule. Entry notice dated 2020-02-06, published 2020-03-11. Article URL retains the old 1976 date; entry-notice URL retains 2018 although its printed notice is from 2020. Replaces the convention signed 1975-12-23 and its closing protocol. The retained entry notice states their expiry at the end of 2019-12-15; treaty Article 30(3) preserves application to earlier tax periods. No old treaty body is used. Roster II V denotes a negotiating protocol, not an operative amendment. Later amendments, MLI effects and developments after the 2026-01-01 roster snapshot have not been exhaustively verified. Unreviewed machine transcription. Original 2018 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, public indexing or deployment approval. Preview only; noindex is not access control. The new 26-page source contains German and French. Both are transcribed from this 2018 PDF only. Closing page 21 declares German, Arabic and French authentic; French prevails in divergent German/Arabic interpretation. Arabic is linked separately by BMF but was NOT fetched or parsed. No complete authentic-language-set claim, English text or translation. Replaces the convention signed 1975-12-23 and its closing protocol. The retained entry notice states their expiry at the end of 2019-12-15; treaty Article 30(3) preserves application to earlier tax periods. No old treaty body is used. Roster II V denotes a negotiating protocol, not an operative amendment. Later amendments, MLI effects and developments after the 2026-01-01 roster snapshot have not been exhaustively verified.
Protocols and later instruments
Replaces the convention signed 1975-12-23 and its closing protocol. The retained entry notice states their expiry at the end of 2019-12-15; treaty Article 30(3) preserves application to earlier tax periods. No old treaty body is used. Roster II V denotes a negotiating protocol, not an operative amendment. Later amendments, MLI effects and developments after the 2026-01-01 roster snapshot have not been exhaustively verified. Source-triage warnings: Unreviewed machine transcription. Original 2018 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, public indexing or deployment approval. Preview only; noindex is not access control. The new 26-page source contains German and French. Both are transcribed from this 2018 PDF only. Closing page 21 declares German, Arabic and French authentic; French prevails in divergent German/Arabic interpretation. Arabic is linked separately by BMF but was NOT fetched or parsed. No complete authentic-language-set claim, English text or translation. Replaces the convention signed 1975-12-23 and its closing protocol. The retained entry notice states their expiry at the end of 2019-12-15; treaty Article 30(3) preserves application to earlier tax periods. No old treaty body is used. Roster II V denotes a negotiating protocol, not an operative amendment. Later amendments, MLI effects and developments after the 2026-01-01 roster snapshot have not been exhaustively verified. Known related/later instruments NOT included in this source (agent triage, not exhaustive): future-instrument-or-negotiation-not-operative; limit: 2026-01-01 roster II V is negotiation, not signature or operative amendment / authentic-language-not-retained; limit: BMF separately links Arabic variant. Not fetched or parsed. Missing Arabic does not turn this complete DE/FR source into a full authentic-language set.
BGBl. 2018 II S. 710 (consent law); S. 711–735 (convention and protocol) | de-tunisia-2018-base | de-tunisia-2018-base | BGBl. 2018 II S. 710 (consent law); S. 711–735 (convention and protocol) | signed 2018-02-08 | published 2018-12-28 | Signed: 2018-02-08 | Gazette publication: 2018-12-28 | Article 8 | fr | Pending independent qualified human wording, completeness, currentness, alignment and rendering review. No human approvals. | /library/treaties/de-tunisia-2018-base/fr/articles/article-8/
Source, edition and limits
Source edition
de-tunisia-2018-base | BGBl. 2018 II S. 710 (consent law); S. 711–735 (convention and protocol) | signed 2018-02-08 | published 2018-12-28 | Signed: 2018-02-08 | Gazette publication: 2018-12-28
Source form
Official original-publication PDF with native text layer; machine reader is not the facsimile
Source scope
Consent law, German/French replacement convention and integral protocol; not consolidated current law
Retrieved
2026-10-01
Text and language scope
Unreviewed machine transcription. Original 2018 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, public indexing or deployment approval. Preview only; noindex is not access control. The new 26-page source contains German and French. Both are transcribed from this 2018 PDF only. Closing page 21 declares German, Arabic and French authentic; French prevails in divergent German/Arabic interpretation. Arabic is linked separately by BMF but was NOT fetched or parsed. No complete authentic-language-set claim, English text or translation. Native spans, line breaks and hyphens are retained without wording correction; recorded coordinate-based word gaps separate adjacent native spans. Complete law, preamble, closing, protocol, shared signatures and running notices: /review/de-tunisia-2018-base/.
Review status
Pending independent qualified human wording, completeness, currentness, alignment and rendering review. No human approvals.
Currentness
Original source edition; not a verified current-law consolidation. Signed 2018-02-08; consent law 2018-12-11; gazette publication 2018-12-28. Treaty entry 2019-12-16, not application. Roster general application 2020-01-01 is not a universal tax-specific rule. Entry notice dated 2020-02-06, published 2020-03-11. Article URL retains the old 1976 date; entry-notice URL retains 2018 although its printed notice is from 2020. Replaces the convention signed 1975-12-23 and its closing protocol. The retained entry notice states their expiry at the end of 2019-12-15; treaty Article 30(3) preserves application to earlier tax periods. No old treaty body is used. Roster II V denotes a negotiating protocol, not an operative amendment. Later amendments, MLI effects and developments after the 2026-01-01 roster snapshot have not been exhaustively verified. Unreviewed machine transcription. Original 2018 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, public indexing or deployment approval. Preview only; noindex is not access control. The new 26-page source contains German and French. Both are transcribed from this 2018 PDF only. Closing page 21 declares German, Arabic and French authentic; French prevails in divergent German/Arabic interpretation. Arabic is linked separately by BMF but was NOT fetched or parsed. No complete authentic-language-set claim, English text or translation. Replaces the convention signed 1975-12-23 and its closing protocol. The retained entry notice states their expiry at the end of 2019-12-15; treaty Article 30(3) preserves application to earlier tax periods. No old treaty body is used. Roster II V denotes a negotiating protocol, not an operative amendment. Later amendments, MLI effects and developments after the 2026-01-01 roster snapshot have not been exhaustively verified.
Protocols and later instruments
Replaces the convention signed 1975-12-23 and its closing protocol. The retained entry notice states their expiry at the end of 2019-12-15; treaty Article 30(3) preserves application to earlier tax periods. No old treaty body is used. Roster II V denotes a negotiating protocol, not an operative amendment. Later amendments, MLI effects and developments after the 2026-01-01 roster snapshot have not been exhaustively verified. Source-triage warnings: Unreviewed machine transcription. Original 2018 publication only, not a verified current-law consolidation. No qualified human wording, legal, alignment, public indexing or deployment approval. Preview only; noindex is not access control. The new 26-page source contains German and French. Both are transcribed from this 2018 PDF only. Closing page 21 declares German, Arabic and French authentic; French prevails in divergent German/Arabic interpretation. Arabic is linked separately by BMF but was NOT fetched or parsed. No complete authentic-language-set claim, English text or translation. Replaces the convention signed 1975-12-23 and its closing protocol. The retained entry notice states their expiry at the end of 2019-12-15; treaty Article 30(3) preserves application to earlier tax periods. No old treaty body is used. Roster II V denotes a negotiating protocol, not an operative amendment. Later amendments, MLI effects and developments after the 2026-01-01 roster snapshot have not been exhaustively verified. Known related/later instruments NOT included in this source (agent triage, not exhaustive): future-instrument-or-negotiation-not-operative; limit: 2026-01-01 roster II V is negotiation, not signature or operative amendment / authentic-language-not-retained; limit: BMF separately links Arabic variant. Not fetched or parsed. Missing Arabic does not turn this complete DE/FR source into a full authentic-language set.
BGBl. 2018 II S. 710 (consent law); S. 711–735 (convention and protocol) · /library/originals/7de0880f35d30dae25056ec347b7326f84b2954a72c6bf746e6213407a3b2a73.pdf
Disclaimers
Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.
Source-page links are references, not human paragraph verification.