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France - Germany Tax Treaty (as amended through 2015 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.



(1) Royalties and other remuneration for the use of or for the right to use copyrights in literacy, artistic or scientific works, including cinematograph films, patents, trademarks, brands, designs, patterns, plans, secret processes or formulae or any similar property or rights shall be taxable only in the Contracting State of which the recipient is a resident.

(2) Royalties shall be deemed to include rentals and similar remuneration for the use of or for the right to use industrial, commercial or scientific equipment or for the provision of information concerning industrial, commercial or scientific experience.

(3) Variable or fixed payments for the working of mines, quarries or other natural resources shall not be deemed to constitute royalties.

*(4) Paragraphs (1) to (3) shall not apply if the recipient of the royalties or other remuneration maintains in the Contracting State in which the income arises a permanent establishment or fixed place of business for the performance of professional services or other activities of an independent character and the royalties or other remuneration are attributable to that permanent establishment or fixed place. In such case, that State has the right to tax such income.

*(5) [DELETED]