09 abr Germany Double Tax Agreements
In many cases, the wording of the provisions is not easy to understand and complex. There are many exceptions. Both for individuals who earn income abroad (for example. B dividends or even wages) than for companies that are setting up internationally – or planning – it is worth taking a closer look at double taxation agreements. In the meantime, the Federal Republic of Germany has concluded double taxation agreements and/or tax treaties with more than 100 countries. The list of all agreements is available on the website of the Federal Ministry of Finance. Through its tax law, Germany intends to avoid both double taxation and double non-taxation of individuals and businesses. Everyone must pay their fair share of the tax in their place of residence or in the place where they operate. This page provides information on German double taxation conventions and other country-specific publications on double taxation conventions. You can view the original texts via our German website. (6) Nothing in the Convention should be interpreted in such a way that the Federal Republic of Germany levies its taxes on the amounts contained in the income of a federal citizen residing in the Federal Republic of Germany under paragraphs 4, 5 and 7 of the «External Taxation Act». Where such taxation results in double taxation, the competent authorities consult the elimination of this double taxation in accordance with Article 25, paragraph 3 (procedure of mutual agreement).
Germany is entitled to all the benefits of a comprehensive convention to avoid double taxation between a Member State. B of the European Union or a European Economic Area state or a contracting party to the North American and State Free Trade Agreement; the benefits of this agreement covered in paragraph (a), (b), (b), (c) or paragraph (e) of this article, unless this agreement contains a general limitation on the purpose of benefits, the qualified person subject to paragraph (a), paragraph (a) (c) (c) of paragraph 2 of this article, if that person resides in one of the States covered by Article 4 (resident) of that convention; (B) with respect to insurance premiums and income covered by Section 10 (dividends), 11 (interest) or 12 (royalties) of this agreement, would be entitled to a tax rate for the special income class for which benefits under this agreement are paid at least equal to the rate applicable under this Convention; or four.