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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.



(1) For the purposes of this Convention:

  • (a) the terms "a Contracting State" and "the other Contracting State" mean, as the context requires, the Federal Republic of Germany or the Union of Soviet Socialist Republics and, when used in a geographical sense, the territory of the respective Contracting State and the continental shelf adjacent to its territorial waters, to the extent that that Contracting State exercises its authority in accordance with international law to explore the continental shelf and to exploit its natural resources;
  • (b) the term "international traffic" means any transport by a ship, boat or aircraft operated by a person who has its place of effective management in one of the Contracting States, except when the transport only takes place between places within one of the Contracting States;
  • (c) the term "competent authorities" means:
    • (i) in the case of the Federal Republic of Germany, the Federal Minister of Finance;
    • (ii) in the case of the Union of Soviet Socialist Republics, the Ministry of Finance of the U.S.S.R. or its authorized representative.

(2) For the application of this Convention by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State, in particular concerning the taxes to which the Convention applies.