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Estonia - Germany Tax Treaty (as amended by 2020 protocol) — Orbitax Tax Hub

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.


Members of Diplomatic Missions and Consular Posts

(1) Nothing in this Agreement shall affect the fiscal privileges of members of a diplomatic mission, a consular post or an international organisation under the general rules of international law or under the provisions of special agreement.

(2) Notwithstanding the provisions of Article 4, an individual who is a member of a diplomatic mission or a consular post of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed for the purposes of the Agreement to be a resident of the sending State if:

  • (a) In accordance with international law he is not liable to tax in the receiving State in respect of income form sources outside that State, and
  • (b) He is liable in the sending State to the same obligations in relation to tax on his world income as are residents of that State.