background image
CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
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.


Deeds and Judgments

Where a deed or judgment made or rendered in a Member State is submitted for the formality of registration in another Member State, the duties applicable in the last-mentioned State shall be determined in accordance with the provisions of its domestic law, except for the deduction, where appropriate, of registration fees that have been levied in the first mentioned State, from the duties due in the second State.

However, deeds or judgments pertaining to the transfer of property, usufruct of real estate or business assets, those (i.e. deeds) bearing transfer of use/enjoyment of buildings and deeds or judgments recording a transfer of right to lease or to benefit from a pledge to lease pertaining to the whole or part of a building/property may only be subject to a transfer tax in the Member State in whose territory the immovable property or business assets are situated.

The provisions of the first sub paragraph of this Article shall not apply to acts of companies or amendments thereto. These acts shall only give rise to the levy of capital duty in the State where the registered office of the company is situated. In case of a merger or similar operations, the tax shall be levied in the State in which the headquarters of the acquiring or new company is located.