DT8020 - Germany, Federal Republic: double taxation agreement, Article 20: Non-discrimination
(1) The nationals of one of the Contracting States shall not be subjected in the other State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected.
(2) The term `nationals` means
(a) in relation to the Federal Republic, all Germans within the meaning of Article 116(1) of the Basic Law for the Federal Republic of Germany, and all legal persons, partnerships and associations deriving their status as such from the law in force in the Federal Republic;
(b) in relation to the United Kingdom, all British subjects and British protected persons
(i) residing in the United Kingdom or any territory to which the present Convention is extended under Article 21 or
(ii) deriving their status as such from connection with the United Kingdom or any territory to which the present Convention is extended under Article 21,
and all legal persons, partnerships and associations deriving their status as such from the law in force in the United Kingdom or in any territory to which the Convention is extended under Article 21.
(3) The taxation on a permanent establishment which an enterprise of one of the territories has in the other territory shall not be less favourably levied in that other territory than the taxation levied on enterprises of that other territory carrying on the same activities. This provision shall not be construed as obliging one Contracting State to grant to residents of the territory of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
(4) Enterprises of one of the territories, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other territory, shall not be subjected in the first-mentioned territory to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of that first-mentioned territory are or may be subjected.
(5) In this Article the term `taxation` means taxes of every kind and description.
