AND CONSIDERING that this Convention entered into force on 26 October 1996, after the two States Parties had agreed on the procedure required by their law under Article 28 of the said Convention: Germany, by its tax law, wishes to avoid both double taxation and double non-taxation of natural and company persons. Everyone must control their fair share of where they live or where they do their business. This paragraph shall not affect the taxation of profits on which dividends are paid. Authority of the territory where he resides. If his claim is deemed eligible, the competent authority with which the claim is invoked shall endeavour to reach an agreement with the competent authority of the other region in order to avoid double taxation. 4. This Agreement shall also apply to all identical or substantially similar fees levied after the date of signature of this Agreement in addition to or in place of existing fees. The competent authorities of the States Parties shall inform each other of significant changes in their tax legislation. This Agreement shall not affect the fiscal prerogatives of members of a diplomatic mission, consular representation or international organisation, in accordance with the general rules of international law or the provisions of special agreements. b. other income subject to the same tax treatment as income from shares under the law of the State in which the recipient company is established. 3. The laws in force in one of the Contracting States shall continue to regulate the taxation of income and capital in the Contracting States concerned, except as expressly provided in this Convention.
Me. “international traffic” means any carriage by ship or aircraft operated by an enterprise having its place of effective management in a Contracting State, unless the ship or aircraft is operated exclusively between places in the other Contracting State; 6. An enterprise shall not be considered to have a permanent establishment in a Contracting State only because it operates in that State through a broker, general commission agent or other independent representative, provided that such persons are acting in the course of their ordinary activities and are not agreed upon or taxed in their commercial and financial relations with the enterprise; which deviate from those usually between independent persons….