Treaty detail
Germany - Ireland tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2011-03-30
Effective
2012-11-28
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on direct-ownership thresholds. EU Parent-Subsidiary Directive provides parallel zero treatment in qualifying intra-EU fact patterns.
Interest
Rate: 0%
The treaty generally results in zero source-country withholding on qualifying interest.
Royalties
Rate: 0%
The treaty eliminates source-country royalty withholding under the article.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows OECD model wording.
Other treaty flags
Pension treatment is article-specific.
Seeded article summaries
Article 4
Residence
Defines treaty residence under modern OECD-aligned rules.
Article 4 follows the modern OECD model with anti-abuse provisions.
Article 5
Permanent Establishment
Sets the business-presence threshold with a 12-month construction rule.
The 2011 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 treaty ceilings. EU Parent-Subsidiary Directive provides parallel zero treatment in qualifying cases.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Article 11 typically eliminates source-country withholding.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 eliminates source-country royalty withholding under the article.
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–IE treaty
- TreatyGB–DE treaty
- TreatyGB–IE treaty
- TreatyCA–DE treaty
- TreatyDE–FR treaty
- TreatyDE–NL treaty
- TreatyCH–DE treaty
Primary sources
- BMF: DoppelbesteuerungsabkommenVerified 2026-05-20
- Irish Revenue: double taxation treatiesVerified 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.