Treaty detail
China - Germany tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2014-03-28
Effective
2016-04-06
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on a direct-ownership threshold of 25 percent under the treaty.
Interest
Rate: 10%
The treaty applies a 10 percent ceiling on most interest. Government, central-bank, and qualifying-institution interest may obtain better treatment.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling. A 6 percent reduced rate applies to certain industrial-equipment categories under the article.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows OECD model wording as adapted in the 2014 treaty.
Other treaty flags
Pension treatment is article-specific.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the modernized 2014 wording.
Article 4 reflects modernized OECD-aligned provisions. Residence analysis interacts with China's Place-of-Effective-Management rules.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes both a 12-month construction-site threshold and a service-PE rule for the furnishing of services beyond a defined number of days.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 follows OECD-aligned profit-attribution principles updated by the 2014 treaty.
Article 10
Dividends
Caps source-country dividend withholding at treaty ceilings.
Article 10 produces the 10 percent and 5 percent treaty ceilings. China's domestic dividend rules continue to apply where treaty conditions are not satisfied.
Article 11
Interest
Limits source-country withholding on qualifying interest to a 10 percent ceiling.
Article 11 produces a 10 percent ceiling with carve-outs for government and central-bank interest under the article.
Article 12
Royalties
Caps royalties at treaty ceilings that vary with category.
Article 12 limits royalties at 10 percent generally with a 6 percent reduced rate for certain industrial-equipment categories. Category classification matters significantly.
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–DE treaty
- TreatyUS–CN treaty
- TreatyGB–DE treaty
- TreatyGB–CN treaty
- TreatyCA–DE treaty
- TreatyCA–CN treaty
- TreatyAU–CN treaty
- TreatyDE–FR treaty
Primary sources
- BMF: DoppelbesteuerungsabkommenVerified 2026-05-20
- State Taxation Administration of ChinaVerified 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.