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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.


Entry into Force

(1) This Agreement shall be ratified and the instruments of ratification shall be exchanged at Bonn as soon as possible.

(2) This Agreement shall enter into force one month after the date of exchange of the instruments of ratification and shall have effect for the first time:

  • (a) In respect of taxes withheld at source, to amounts paid after December 31 of the year in which it enters into force;
  • (b) In respect of other taxes, to taxable years beginning on or after January 1 of the year following the year in which it enters into force.

(3) Upon the entry into force of this Agreement the Agreement between the Federal Republic of Germany and the United Arab Republic (Egyptian Province) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income of November 17, 1959, shall expire and shall cease to have effect as from the dates on which the provisions of this Agreement commence to have effect.