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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.


The Franco-German convention of 9 November 1934 concerning avoidance of double taxation and reciprocal administrative assistance in connection with direct taxation is hereby abrogated. Tax payments, the postponement of which has been accorded by either of the Contracting States in accordance with the provisions of paragraph (15) of the Final Protocol of that Convention shall be deemed to be remitted in full. The provisions of the Convention under which such postponements are accorded shall apply for the last time to:

  • (1) Taxes levied on the income from movable capital referred to in Article 9 of the Convention, paid before 1 January 1958;
  • (2) Other French taxes established for the calendar year 1956;
  • (3) Other German taxes levied for the calendar year 1956.

IN WITNESS WHEREOF, the plenipotentiaries of the two States have signed this Convention and have thereto affixed their seals.

DONE in Paris on the twenty-first day of July 1959 in duplicate in the French and German languages, both texts being equally authentic.