ARTICLE 32

Entry Into Force

(1) This Convention shall be ratified; instruments of ratification shall be exchanged as soon as possible in Berlin.

(2) The Convention shall enter into force on the day of the exchange of the instruments of ratification and shall have effect:

• (a) in Germany:
  • (aa) in the case of taxes withheld at source, in respect of amounts paid on or after 1 January of the calendar year next following that in which the Convention enters into force;
  • (bb) in the case of other taxes, in respect of taxes levied for periods beginning on or after 1 January of the calendar year next following that in which the Convention enters into force;
• (b) in the United Kingdom:
  • (aa) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6 April in the calendar year next following that in which the Convention enters into force;
  • (bb) in respect of corporation tax, for any financial year beginning on or after 1 April in the calendar year next following that in which the Convention enters into force;
  • (cc) in respect of taxes withheld at source, to income derived on or after 1 January in the calendar year next following that in which the Convention enters into force.

(3) The Convention between the United Kingdom of Great Britain and Northern Ireland and the Federal Republic of Germany signed at Bonn on 26 November 1964 as amended by the Protocol signed at London on 23 March 1970 (hereinafter referred to as the 1964 Convention) shall expire and cease to be effective from the date upon which this Convention has effect in respect of the taxes to which this Convention applies in accordance with the provisions of paragraph (2).

(4) Notwithstanding the provisions of paragraphs (2) and (3) an individual who is entitled to the benefits of Article XIII of the 1964 Convention at the time of entry into force of this Convention shall continue to be entitled to such benefits as if the 1964 Convention had remained in force.

(5) Notwithstanding the provisions of paragraphs (2) and (3) and the provisions of Article 17, where, immediately before the entry into force of this Convention, an individual was in receipt of payments falling within Article X of the 1964 Convention, that individual may elect that the provisions of Article X shall continue to apply to those payments, and not the provisions of Article 17.