DT Agreements: Germany - Income from a UK source paid to a resident of Germany
UK interest paid to a resident of Germany
Full relief from UK tax is available for UK interest that is paid to a resident of Germany provided that the interest is ‘subject to tax’ in Germany. See Article VII.
If the owner of the interest is not subject to tax - see INTM162090 for an explanation of ‘subject to tax’ - in Germany in respect of an interest payment no relief is available.