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Germany and China have a long history of trade relations that culminated in the conclusion of their first double taxation agreement in 1985. In order to improve economic relations, the two States Parties have renewed their treaty over the past year. The new double taxation convention between Germany and China was adopted on 1 January 2015. The taxes covered by the Germany-China double taxation agreement are: 3. Shipping and air transport The new DTT has added a subsection under the shipping and air transport item to define the amount of profits from maritime and air transport. 4. Associated Companies The Associated Enterprises clause is intended to deal with transfer pricing (“TP”). In other words, the adjustment of taxable profits made by a contracting state for TP reasons is permitted. The new DTT indicates that the other country is making an appropriate tax adjustment in the opposite direction.

5. Dividends According to the former DTT, dividends can be taxed in the country of origin and the tax collected by the country of origin may not exceed 10% of the gross dividend. The new DTT lowered the tax rate to 5% if the owner receiving the dividends (since it is a corporate tax) directly owns 25% or more of the private equity company`s company. Otherwise, the tax rate is still 10%. It should be noted that the 5% tax rate does not apply to a partnership or similar business, even though it may hold more than 25% of capital in the company that pays dividends. The new DTT also looks at the issue of dividends distributed by an investment instrument (for example. B real estate investment fund) for which the profits (from which dividends are paid) come from real estate. In certain circumstances, the beneficiary of the dividends cannot be protected by the 10% or 5% tax rate for dividends received by the investment instrument. 6. The interest rates of the former DTT are limited to 10% of the tax rate on savings income levied by the source company. Tax legislation is paid by the country of origin for interest (1) to the other government, (2) for loans paid by the government of the other state or by financial institutions 100% owned by the other state (3) of certain financial institutions specifically listed in the DTT.

The new DTT added a subsection under this clause stipulating that the country of origin does not have tax legislation on interest collected for deferred payments related to the purchase of commercial and scientific equipment. 7. Charges The tax levied by the country of origin for royalties is still limited to 10% of the gross amount. However, for equipment rentals, the effective tax rate is reduced from 7% to 6%. 8. Capital gains Under the former DTT, capital gains from the transfer of shares may be taxed by the country of origin. The new DTT provides for different rules: are profits derived from the transfer of shares/rights of a company whose assets are mainly (over 50%) 2000. Real estate can be taxed by the country where the land is located. For the transfer of shares other than those mentioned above, the country of origin has the right to tax capital gains if the ratio between the shareholding is (directly or indirectly) 25% or more than 25% (in the 12 months prior to the transfer of shares). In other words, in this case, the tax can be collected by the country in which the transferred company is established. One exception is the transfer of shares listed on a recognized exchange for which the country of origin waives the right of taxation when shares carried over by a resident of the other state in a fiscal year represent less than 3% of the outstanding shares of the listed company.

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