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Germany - Slovenia Tax Treaty (as amended by 2011 protocol) — Orbitax Tax Hub

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.


Taxes Covered

(1) This Agreement shall apply to taxes on income and on capital imposed on behalf of a Contracting State, of a land or a political subdivision or local authority thereof, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which this Agreement shall apply are in particular:

  • (a) in the Federal Republic of Germany:
    • (i) the income tax (Einkommensteuer);
    • (ii) the corporation tax (Körperschaftsteuer);
    • (iii) the trade tax (Gewerbesteuer); and
    • (iv) the capital tax (Vermögensteuer); including the supplements levied thereon
  • (hereinafter referred to as "German tax");
  • (b) in the Republic of Slovenia:
    • (i) the tax on profits of legal persons (davek od dobicka pravnih oseb);
    • (ii) the tax on income of individuals, including wages and salaries, income from agricultural activities, income from business, capital gains and income from immovable and movable property (dohodnina); and
    • (iii) the tax on property (davek od premozja);
  • (hereinafter referred to as "Slovenian tax").

(4) The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall-if necessary for the application of the Agreement-notify each other of changes which have been made in their respective taxation laws.