background image

Germany - Georgia Tax Treaty (as amended by 2014 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.

ARTICLE 28

APPLICATION OF THE CONVENTION IN SPECIAL CASES

(1) This Convention shall not be construed so as to prevent a Contracting State from applying the provisions of its national law on the prevention of tax evasion or tax fraud.

(2) Should the provisions of paragraph (1) result in double taxation, the competent authorities shall consult together, in accordance with paragraph (3) of Article 25, with a view to the avoidance of double taxation.