পাতা:বাংলাদেশ গেজেট, অতিরিক্ত, জানুয়ারী ২, ১৯৯৪.pdf/২২

এই পাতাটির মুদ্রণ সংশোধন করা প্রয়োজন।

Protocol The People's Republic of Bangladesh and The Federal Republic of Germany Have Agreed at the Signing at Bonn on May 29, 1990, of the Agreement between the two States for the avoidance of double taxation with respect to taxes on income upon the following provisions which shall form an integral part of the said Agreement. 1. - With reference to Article 10 in the case of the Federal Republic of Germany the term “dividends” shall also include income derived by a sleeping partner from his participation as such. With reference to Articles 10 and 11 notwithstanding the provisions of these Articles, dividends and interest may be taxed in the Contracting State in which they arise, and according to the law of that State, if they are derived from rights or debt claims carrying a right to participate in profits (including income derived by a sleeping partner from his participation as such, from a “partiarisches Darlehen" and from "Gewinnobligationen” within the meaning of the law of the Federal Republic of Germany) and under the condition that they are deductible in the determination of profits of the debtor of such In Com-. with reference to Article 22 where a company being a resident of the Federal Republic of Germany distributes income derived from sources within Bangladesh paragraph 1 shall not preclude the compensatory imposition of corporation tax on such distributions in accordance with the provisions of German tax law: In case Bangladesh changes its law to avoid economic double, taxation, similar appropriate provisions in respect of paragraph 2 shall be applicable in its caSc. Done at Bonn, this 29th day of May, 1990, in two originals, each in the Bangla, German and English languages, all texts being authentic. In case of any divergence of interpretation, the English textshall prevail. For the People's Republic of For the Federal Republic of Germany Bangladesh Mu7.AMIME :-iss ATM Dr. HANS WERNER LAUTENSCHLAGER