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United Kingdom - Germany Tax Treaty (as amended through 2021 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.


Taxes Covered

(1) This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State, of a "Land" or a political subdivision or local authority of a "Land" or a Contracting State, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes which are the subject of this Convention are in particular:

  • (a) in the Federal Republic of Germany:
    • (aa) the income tax ("Einkommensteuer");
    • (bb) the corporation tax ("Körperschaftsteuer");
    • (cc) the trade tax ("Gewerbesteuer"); and
    • (dd) the capital tax ("Vermögensteuer");
  • including the supplements levied thereon;
  • (hereinafter referred to as "German tax");
  • (b) in the United Kingdom:
    • (aa) the income tax;
    • (bb) the corporation tax; and
    • (cc) the capital gains tax;
  • (hereinafter referred to as "United Kingdom tax").

(4) This Convention shall also apply to any identical or substantially similar taxes that are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their taxation laws.