Treaty detail
Canada - Germany tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2001-04-19
Effective
2002-03-28
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on a direct-ownership threshold. The treaty is post-2002 and reflects modernized OECD-aligned provisions.
Interest
Rate: 10%
The 10 percent ceiling can be reduced or eliminated for qualifying government, central-bank, and pension-fund interest under the article.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling, with exemptions for certain copyright and computer-software categories.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the OECD model wording.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed pension and social-security provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence under modern OECD-aligned wording.
Article 4 reflects the OECD model and resolves dual-resident entity cases through mutual agreement procedure.
Article 5
Permanent Establishment
Sets the business-presence threshold including a 12-month construction rule.
The treaty uses the standard 12-month construction-site threshold.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 follows the OECD's authorised-approach to profit attribution.
Article 10
Dividends
Caps source-country dividend withholding at treaty ceilings.
Article 10 produces the 15 percent and 5 percent ceilings. The EU Parent-Subsidiary Directive does not apply to Canada-source dividends but Canadian domestic rules can provide their own treatment.
Article 11
Interest
Limits source-country withholding on qualifying interest.
Article 11 produces a 10 percent ceiling with zero treatment for qualifying government, central-bank, and pension-fund interest.
Article 12
Royalties
Caps royalties at a 10 percent ceiling with category exemptions.
Article 12 generally limits royalties to 10 percent but provides exemptions for certain copyright and computer-software categories.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–CA treaty
- TreatyUS–DE treaty
- TreatyGB–CA treaty
- TreatyGB–DE treaty
- TreatyCA–MX treaty
- TreatyAU–CA treaty
- TreatyCA–FR treaty
- TreatyCA–JP treaty
Primary sources
- Canada Department of Finance: tax treatiesVerified 2026-05-20
- BMF: DoppelbesteuerungsabkommenVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.