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Ireland - 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 Agreement 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 Contracting State or a "Land", 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 to which the Agreement shall apply are in particular:

  • (a) in the case of Ireland:
    • (i) the income tax;
    • (ii) universal social charge;
    • (iii) the corporation tax; and
    • (iv) the capital gains tax;
  • (hereinafter referred to as "Irish tax");
  • (b) in the case of the Federal Republic of Germany:
    • (i) the income tax (Einkommensteuer);
    • (ii) the corporation tax (Körperschaftsteuer);
    • (iii) the trade tax (Gewerbesteuer); and
    • (iv) the capital tax (Vermögensteuer);
  • including the supplements levied thereon
  • (hereinafter referred to as "German tax").

(4) The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Agreement 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 that have been made in their taxation laws.