(1) Dividends paid by a company which is a resident of a Con-
tracting 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 bene-
ficial 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 bene-
ficial owner is a company (other than a partnership) which
holds directly at least 10 per cent of the capital of the com -
pany paying the dividends;
b) 10 per cent of the gross amount of the dividends if the bene -
ficial owner is a pension scheme;
c) 15 per cent of the gross amount of the dividends in all other
cases.
The provisions of this paragraph shall not affect the taxation of
the company in respect of the profits out of which the dividends
are paid.
(3) The term “dividends” as used in this Article means income
from shares, “jouissance” shares or “jouissance” rights, mining
shares, founders’ shares or other item which is subjected to the
same taxation treatment as income from shares by the laws of
the State of which the company making the distribution is a resi -
dent, and income from distributions on certificates of a German
“Investmentvermögen”.
(4) The provisions of paragraphs 1 and 2 shall not apply if the
beneficial owner of the dividends, being a resident of a Contract-
ing State, carries on business in the other Contracting State of
which the company paying the dividends is a resident, through a
permanent establishment situated therein and the holding in re-
spect of which the dividends are paid is effectively connected
with such permanent establishment. In such case the provisions
of Article 7 shall apply.
(5) 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 situated in that other State, nor sub-
ject the company's undistributed profits to a tax on the com -
pany’s undistributed profits, even if the dividends paid or the
undistributed profits consist wholly or partly of profits or income
arising in such other State.
(6) No relief shall be available under this Article if it was the
main purpose or one of the main purposes of any person con-
cerned with the creation or assignment of the shares or other
rights in respect of which the dividend is paid to take advantage
of this Article by means of that creation or assignment.
de-united-kingdom-2010-base | BGBl. 2010 II S. 1333 | Signed: 2010-03-30 | Gazette publication: 2010-11-23
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
German and English versions are present in the source and are identified by the signing 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-united-kingdom-2010-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. 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 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: 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: 2014-03-17; entry into force: 2015-12-29; general application from: 2016-01-01; limit: Exact tax-specific application remains for protocol review. / amending-protocol; signature date: 2021-01-12; entry into force: 2021-12-17; general application from: 2022-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2010 II S. 1333 | de-united-kingdom-2010-base | de-united-kingdom-2010-base | BGBl. 2010 II S. 1333 | Signed: 2010-03-30 | Gazette publication: 2010-11-23 | Article 10 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-united-kingdom-2010-base/en/articles/article-10/
Source, edition and limits
Source edition
de-united-kingdom-2010-base | BGBl. 2010 II S. 1333 | Signed: 2010-03-30 | Gazette publication: 2010-11-23
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
German and English versions are present in the source and are identified by the signing 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-united-kingdom-2010-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. 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 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: 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: 2014-03-17; entry into force: 2015-12-29; general application from: 2016-01-01; limit: Exact tax-specific application remains for protocol review. / amending-protocol; signature date: 2021-01-12; entry into force: 2021-12-17; general application from: 2022-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription