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 22
Remittance Clause
(1) Where this Agreement provides (with or without other conditions) that income from sources in a Contracting State shall be exempt from tax, or taxed at a reduced rate, in that State and under the laws in force in the other Contracting State they said income is subject to tax by reference to the amount thereof which is remitted to or received in that other State and not by reference to the full amount thereof, then the exemption or reduction of tax to be allowed under this Agreement in the first-mentioned State shall apply only to so much of the income as is remitted to or received in the other State.
*(2) Paragraph (1) above shall not be construed to apply:
- (a) in the case of Singapore:
- (aa) when Singapore exempts income referred to in sub-paragraph (b) of paragraph (2) of Article 24 of the Agreement; in such case, the exemption or reduction of tax to be allowed under this Agreement in the Federal Republic of Germany shall apply to the amount of income from sources in the Federal Republic of Germany that is exempted from tax in Singapore; and
- (bb) to income derived by the Government of Singapore and any statutory body thereof, GIC Private Limited, and the Central Bank of Singapore; and
- (b) in the case of the Federal Republic of Germany, to income derived by the Federal Republic of Germany, a Land, a political subdivision or a local authority thereof.