1. Notwithstanding the provisions of Articles 15 (Dependent
Personal Services), 16 (Directors’ Fees), and 17 (Artistes and
Athletes):
a) salaries, wages and other similar remuneration, other than a
pension, paid by a Contracting State or a political sub-
division, local authority or an instrumentality thereof to an
individual in respect of services rendered to that Contracting
State or a political subdivision, local authority or an
instrumentality thereof shall, subject to the provisions of
subparagraph b), be taxable only in that State;
b) such remuneration, however, shall be taxable only in the
other Contracting State if the services are rendered in that
State and the individual is a resident of that State who:
aa) is a national of that State; or
bb) did not become a resident of that State solely for the
purpose of rendering the services.
2.
a) Notwithstanding the provisions of paragraph 1, pensions
and other similar remuneration paid by, or out of funds
created by, a Contracting State or a political subdivision,
local authority or an instrumentality thereof to an individual
in respect of services rendered to that State or subdivision,
authority or instrumentality shall be taxable only in that
State.
b) However, such pensions and other remuneration shall be
taxable only in the other Contracting State if the individual
is a
aa) resident of, and a national of, that State; or
bb) the pension is not subject to tax in the Contracting
State for which the services were performed because
the services were performed entirely in the other
Contracting State.
3. Pensions, annuities, and other amounts paid by one of the
Contracting States or by a juridical person organized under the
public laws of that State as compensation for an injury or
damage sustained as a result of hostilities or political
persecution shall be exempt from tax by the other State.
4. The provisions of Articles 15 (Dependent Personal
Services), 16 (Directors’ Fees), 17 (Artistes and Athletes),
and 18 (Pensions, Annuities, Alimony, Child Support, and Social
Security) shall apply to salaries, wages and other similar
remuneration, and to pensions, in respect of services rendered
in connection with a business carried on by a Contracting State
or by a political subdivision, local authority or an instrumentality
thereof.
5. In this Article, the term “instrumentality” means any agent
or entity created or organized by a Contracting State, one of its
states or a political subdivision or local authority thereof in order
to carry out functions of a governmental nature which is
specified and agreed to in letters exchanged between the
competent authorities of the Contracting States.
BGBl. 2008 II S. 611 | Included protocol entered 2007-12-28 (original publication footnote, PDF31); publication 2008-06-23; correction851 unresolved | Signed: 1989-08-29 | Gazette publication: 2008-06-23
Source form
Original official-publication PDF with native text layer; unreviewed language-separated machine transcription of that exact publication
Source scope
Exact officially published consolidation, not a privately synthesized or certified current-law text
Retrieved
2026-09-30
Text and language scope
UNREVIEWED ORIGINAL 611-PUBLICATION ONLY. Correction BGBl.2008 II S.851 is identified but its wording/incorporation is unresolved. NOT a corrected final version or current law. Printed line breaks, hyphens and PDF word spacing retained. Article14 deletion marker and Article18A conserved. Separate preamble, protocol and publication footnotes: /review/de-united-states-2008-consolidated/. No consolidation closing or signatories invented. Page references are not verified paragraph alignment.
Review status
Pending qualified human review; no wording, completeness, legal alignment or indexing approval.
Currentness
Original source edition; not a verified current-law consolidation. No current-law determination, qualified human wording/completeness review, legal alignment, or indexing approval. No exhaustive later-development check. Page links identify source pages, not verified paragraph correspondence. Original 611 publication only; Correction851 unresolved. No corrected-final-version or full-language accuracy claim. 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
Includes protocol signed 2006-06-01, entry 2007-12-28 (publication footnote4, PDF31). Separate official correction BGBl.2008 II S.851 is linked in retained BMF metadata; its wording and incorporation remain unresolved. No correction applied. 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
BGBl. 2008 II S. 611 | de-united-states-2008-consolidated | BGBl. 2008 II S. 611 | Included protocol entered 2007-12-28 (original publication footnote, PDF31); publication 2008-06-23; correction851 unresolved | Signed: 1989-08-29 | Gazette publication: 2008-06-23 | Article 19 | en | Pending qualified human review; no wording, completeness, legal alignment or indexing approval. | /library/treaties/de-united-states-2008-consolidated/en/articles/article-19/
Source, edition and limits
Source edition
BGBl. 2008 II S. 611 | Included protocol entered 2007-12-28 (original publication footnote, PDF31); publication 2008-06-23; correction851 unresolved | Signed: 1989-08-29 | Gazette publication: 2008-06-23
Source form
Original official-publication PDF with native text layer; unreviewed language-separated machine transcription of that exact publication
Source scope
Exact officially published consolidation, not a privately synthesized or certified current-law text
Retrieved
2026-09-30
Text and language scope
UNREVIEWED ORIGINAL 611-PUBLICATION ONLY. Correction BGBl.2008 II S.851 is identified but its wording/incorporation is unresolved. NOT a corrected final version or current law. Printed line breaks, hyphens and PDF word spacing retained. Article14 deletion marker and Article18A conserved. Separate preamble, protocol and publication footnotes: /review/de-united-states-2008-consolidated/. No consolidation closing or signatories invented. Page references are not verified paragraph alignment.
Review status
Pending qualified human review; no wording, completeness, legal alignment or indexing approval.
Currentness
Original source edition; not a verified current-law consolidation. No current-law determination, qualified human wording/completeness review, legal alignment, or indexing approval. No exhaustive later-development check. Page links identify source pages, not verified paragraph correspondence. Original 611 publication only; Correction851 unresolved. No corrected-final-version or full-language accuracy claim. 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
Includes protocol signed 2006-06-01, entry 2007-12-28 (publication footnote4, PDF31). Separate official correction BGBl.2008 II S.851 is linked in retained BMF metadata; its wording and incorporation remain unresolved. No correction applied. 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