Treaty detail
United Kingdom - Germany tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2010-03-30
Effective
2010-12-30
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on direct ownership above the treaty threshold. EU Parent-Subsidiary Directive may apply to provide zero treatment in qualifying intra-EU/UK fact patterns despite post-Brexit nuances.
Interest
Rate: 0%
The treaty generally results in zero source-country withholding on qualifying interest, subject to beneficial-ownership and treaty-qualification analysis.
Royalties
Rate: 0%
The treaty generally eliminates source-country withholding on qualifying royalties across the major categories.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis under the modernized treaty wording, as updated by the 2021 protocol, follows BEPS-era principles on habitual conclusion of contracts.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed pension, government-service, and social-security articles.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 2010 OECD-aligned wording.
Article 4 follows the modern OECD model. The 2021 protocol updated certain residence-tie-breaker provisions to align with BEPS-era best practices.
Article 5
Permanent Establishment
Sets the business-presence threshold including a 12-month construction rule and modernized agency wording.
The 2010 treaty uses the standard 12-month construction threshold. The dependent-agent rule was further updated by the 2021 protocol to align with BEPS-era anti-fragmentation thinking.
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, with explicit reference to functions, assets, and risks of the PE.
Article 10
Dividends
Caps source-country withholding on dividends at treaty ceilings, with EU Directive interplay.
Article 10 produces 15 percent and 5 percent ceilings depending on direct ownership. Where the EU Parent-Subsidiary Directive applies, zero treatment may be available subject to anti-abuse rules.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Article 11 typically eliminates source-country withholding on qualifying interest. The treaty interacts with the EU Interest and Royalties Directive in qualifying cases.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 produces a zero-percent result across the major royalty categories. As with interest, the treaty interacts with the EU Interest and Royalties Directive.
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–GB treaty
- TreatyUS–DE treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC: Germany 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.