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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.


Taxes Covered

(1) This Convention shall apply to taxes on income and on capital, imposed on behalf of a Contracting State or its local authorities, 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 the total income, total capital or on the items of income and capital, including taxes on gains from the alienation of immovable property, taxes on the total amount of salaries paid by enterprises as well as taxes on capital appreciation.

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

  • (a) In the Federal Republic of Germany:
    • (i) the income tax;
    • (ii) the corporate tax;
    • (iii) the business tax;
  • including charges imposed on these taxes.
  • (hereinafter referred to in as "German Taxes");
  • (b) In Turkmenistan:
    • (i) the profit tax (income tax) for legal persons;
    • (ii) the income tax for individuals and the tax on capital;
  • (hereinafter referred to as "Turkmen Taxes").

(4) This Convention shall apply to taxes of an identical or substantially similar nature that are imposed after the date of signing this Convention in addition to, or instead of, the existing taxes. The competent authorities of the Contracting States shall, on a timely basis, notify each other about any significant changes introduced in their respective tax laws.