Application of the Agreement in Special Cases
(1) This Agreement shall not be interpreted to mean that:
- (a) a Contracting State is prevented from applying its domestic legal provisions on the prevention of tax evasion or tax avoidance;
- (b) the Federal Republic of Germany is prevented from levying taxes on amounts which are to be included in the items of income of a resident of the Federal Republic of Germany under the Fourth Part of the German Law on External Tax Relations (Aussensteuergesetz).
(2) If the provisions of paragraph 1 result in double taxation, the competent authorities shall consult each other pursuant to Article 25 paragraph 3 on how to avoid double taxation.