(1) Items of income beneficially owned by a resident of a Con-
tracting State, wherever arising, which are not dealt with in the
foregoing Articles of this Convention shall be taxable only in that
State.
(2) Notwithstanding the provisions of paragraph 1, the follow-
ing provisions shall apply with respect to income paid out of
trusts or the estates of deceased persons in the course of
administration:
Where such income is paid to a beneficiary who is a resident of
Germany by trustees or personal representatives who are
residents of the United Kingdom out of income received by those
trustees or personal representatives which would, if those
trustees or personal representatives had been residents of
Germany, have fallen within other Articles of this Convention, the
beneficiary shall be treated as having received an amount of the
income received by the trustees or personal representatives
corresponding to the income received by him and any tax paid
by the trustees or personal representatives on that amount shall
be treated as having been paid by the beneficiary.
(3) The provisions of paragraph 1 shall not apply to income,
other than income from immovable property as defined in para-
graph 2 of Article 6, if the recipient of such income, being a resi -
dent of a Contracting State, carries on business in the other
Contracting State through a permanent establishment situated
therein and the right or property in respect of which the income
is paid is effectively connected with such permanent establish-
ment. In such case the provisions of Article 7 shall apply.
(4) Where, by reason of a special relationship between the
person referred to in paragraph 1 and some other person, or be-
tween both of them and some third person, the amount of the
income referred to in paragraph 1 exceeds the amount (if any)
which would have been agreed upon between them in the ab-
sence of such a relationship, the provisions of this Article shall
apply only to the last mentioned amount. In such a case, the
excess part of the income shall remain taxable according to the
laws of each Contracting State, due regard being had to the
other applicable provisions of this Convention.
(5) 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 rights in respect
of which the income 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 21 | 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-21/
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