1. Nationals of a Contracting State shall not be subjected in
the other Contracting State to any taxation or any requirement
connected therewith that is other or more burdensome than the
taxation and connected requirements to which nationals of that
other State in the same circumstances are or may be subjected.
Notwithstanding the provisions of Article 1, this provision shall
also apply to persons who are not residents of one or both of
the Contracting States.
2. The taxation on a permanent establishment that an
enterprise of a Contracting State has in the other Contracting
State shall not be less favorably levied in that other State than
the taxation levied on enterprises of that other State carrying on
the same activities. This provision shall not be construed as
obliging a Contracting State to grant to residents of the other
Contracting State any personal allowances, reliefs, and
reductions for taxation purposes on account of civil status or
family responsibilities that it grants to its own residents.
3. Except where the provisions of paragraph 1 of Article 9
(Associated Enterprises), paragraph 4 of Article 11 (Interest), or
paragraph 4 of Article 12 (Royalties) apply, interest, royalties,
and other disbursements paid by an enterprise of a Contracting
State to a resident of the other Contracting State shall, for
purposes of determining the taxable profits of such enterprise,
be deductible under the same conditions as if they had been
paid to a resident of the first-mentioned State. Similarly, any
debts of an enterprise of a Contracting State to a resident of the
other Contracting State shall, for purposes of determining the
taxable capital of such enterprise, be deductible under the
same conditions as if they had been contracted to a resident of
the first-mentioned State.
4. Enterprises of a Contracting State, the capital of which is
wholly or partly owned or controlled, directly or indirectly, by
one or more residents of the other Contracting State, shall not
be subjected in the first-mentioned State to any taxation or any
requirement connected therewith that is other or more
burdensome than the taxation and connected requirements to
which other similar enterprises of the first-mentioned State are
or may be subjected.
6. The provisions of this Article shall, notwithstanding the
provisions of Article 2 (Taxes Covered), apply to taxes of every
kind and description imposed by a Contracting State or a
political subdivision or local authority thereof.
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 24 | en | Pending qualified human review; no wording, completeness, legal alignment or indexing approval. | /library/treaties/de-united-states-2008-consolidated/en/articles/article-24/
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