DT7908A - Double Taxation Relief Manual: Guidance by country: Germany, Federal Republic of: Tax deductible dividends and interest

The agreement provides tax deductible interest and dividends arising in Germany that carry a right to participate in profits may be taxable in Germany. Interest and dividends carrying a right to participate in profits include income:

• derived by a silent partner (“stiller Gesellschafter”) from his participation as such;
• from a loan with an interest rate linked to borrower’s profit (“partiarisches Darlehen”); or
• from profit sharing bonds (“Gewinnobligationen”) within the meaning of the tax law of Germany.