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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 2

Taxes Covered

(1) This Agreement shall apply to taxes on income imposed on behalf of a Contracting State, of a Land or a political subdivision or local authority thereof, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property.

(3) The existing taxes to which this Agreement shall apply are in particular:

  • (a) in the Federal Republic of Germany:
    • (i) the income tax (Einkommensteuer);
    • (ii) the corporation tax (Körperschaftsteuer); and
    • (iii) the trade tax (Gewerbesteuer);
  • including the supplements levied thereon;
  • (hereinafter referred to as "German tax");
  • (b) in the United Arab Emirates:
    • (i) the income tax;
    • (ii) the corporation tax;
  • (hereinafter referred to as "U.A.E. tax").

(4) This Agreement shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their taxation laws.