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 33
Termination
This Agreement shall remain in force until terminated by one of the Contracting States. Either Contracting State may terminate the Agreement, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year beginning after the expiration of a period of five years from the date of entry into force of the Agreement. In such event, this Agreement shall cease to have effect:
- (a) in Ireland:
- (i) in the case of income tax, universal social charge and capital gains tax, for any year of assessment beginning on or after 1 January in the calendar year next following the year in which notice of termination is given;
- (ii) in the case of corporation tax, for any financial year beginning on or after 1 January in the calendar year next following the year in which notice of termination is given;
- (b) in Germany:
- (i) in the case of taxes withheld at source, in respect of amounts paid on or after 1 January in the calendar year next following the year in which notice of termination is given;
- (ii) in the case of other taxes, in respect of taxes levied for periods beginning on or after 1 January in the calendar year next following the year in which notice of termination is given.
Notice of termination shall be regarded as having been given by a Contracting State on the date of receipt of such notice by the other Contracting State.