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HMRC internal manual

Double Taxation Relief Manual

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.