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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.


Entry into Force

(1) This Agreement shall be subject to ratification in accordance with the constitutional requirements of the two Contracting States and the instruments of ratification shall be exchanged at Berlin as soon as possible.

(2) This Agreement shall enter into force upon the exchange of the instruments of ratification and shall have effect in both Contracting States:

  • (a) in the case of taxes withheld at source, in respect of amounts paid after December 31, 1997;
  • (b) in the case of other taxes, in respect of taxes levied for any periods beginning on or after January 1, 1998.