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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) The provisions of this Convention may be extended either wholly or in part with such amendments as may be deemed necessary, to any territory for the international relations of which France is responsible and which levies taxes of the same nature as those which are the subject of this Convention.

(2) The extension of this Convention as provided in paragraph (1) shall be effected by exchange between the Contracting States of diplomatic notes specifying the territory to which the provisions extended shall apply and the conditions of such extension. Provisions extended by exchange of notes as aforesaid, either wholly or in part or with such amendments as may be necessary, shall apply to the specified territory with effect from the date indicated in the notes.

(3) At any time after the expiry of a period of one year from the entry into force of an extension effected in accordance with paragraphs (1) and (2), either of the Contracting States may, by notice in writing to the other Contracting State through the diplomatic channel, terminate the application of the provisions to any of the territories to which they may have been extended-in such case, the provisions shall cease to apply to that territory from 1 January following the date of the notice, provided that such termination shall not affect the application of the said provisions to France and to any other territory not mentioned in the notice to which they may have been extended.

(4) When the provisions of this Convention cease to apply between France and the Federal Republic, they shall also cease to apply to any territory to which they may have been extended in accordance with this Article, except as otherwise expressly decided by the Contracting States.

(5) For the purposes of the application of this Convention in any territory to which it may have been extended, any reference in the Convention to France shall be deemed to apply equally to the said territory.