background image
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.


Government Service

(1) Wages, salaries and other similar remunerations, as well as retirement pensions, paid by a Contracting State, by a "land" or one of its political subdivisions or local authorities, either directly, or by withdrawal on funds which they constitute, to an individual who is a resident of the other State for rendered services are taxable in the first State. These remunerations and pensions are exempt from the tax of the other State whose recipient is a resident when it has the nationality of the first State without having at the same time the nationality of this other State.

(2) The provisions of Articles 15, 16 and 18 shall apply to remunerations or pensions paid in respect of services rendered in connection with a commercial or industrial activity carried on by one of the Contracting States, by a "land" or one of its political subdivisions or local authorities.

(3) Notwithstanding the provisions of paragraph (2), there shall be included in the scope of application of paragraph (1) the remuneration and pensions allocated to their personnel by the organizations the income and expenses of which are included in the general budget of the Contracting State to which they belong, including in the case of the Federal Republic of Germany, the Deutsche Bundesbank, the Deutsche Bundesbahn and the Deutsche Bundespost

(4) Allowances allotted in the form of pensions, life annuities and other services, periodic or not, by a Contracting State, a "land" or a legal entity of public law of this State by reason of damage due to hostilities or political persecutions shall be exempt from the tax of the other Contracting State.