- Draft legislation
This is a draft item of legislation. This draft has since been made as a UK Statutory Instrument: The Double Taxation Relief (Federal Republic of Germany) Order 2021 No. 634
Paragraph 4 of Article 25 shall be deleted and replaced by the following paragraph:
“(4) Except where the provisions of paragraph 1 of Article 9, paragraph 4 of Article 11, paragraph 4 of Article 12, or paragraph 4 of Article 21 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State.”.
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