Convention entre la République fédérale d'Allemagne et la République du Cameroun pour éviter la double imposition des entreprises de transport aérien en matière d'impôts sur le revenu et sur la fortune

Convention

between

the Federal Republic of Germany

and

the Republic of Cameroon

for the Avoidance of Double Taxation of Air Transport Companies with respect to Taxes on Income and Capital

# The Federal Republic of Germany

and

the Republic of Cameroon ,

Desiring to promote and reinforce their economic ties by concluding a Convention for the avoidance of double taxation of air transport enterprises with respect to taxes on income and capital −,

Have agreed as follows:

# Article 1

# Persons covered

This Convention shall apply to enterprises which operate aircraft in international traffic and are residents of one or both of the Contracting States.

# Article 2

# Taxes covered

1. This Convention shall apply to taxes on income and capital imposed on behalf of a Contracting State, one of its Länder or one of their political subdivisions or local authorities, irrespective of the manner in which they are levied.

2.There shall be regarded as taxes on income and capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation. 3.The existing taxes to which the Convention shall apply are in particular:

a) in the Federal Republic of Germany:

i. the income tax (Einkommensteuer);

ii. the corporate income tax (Körperschaftsteuer); ithe trade tax (Gewerbesteuer) and iv. the capital tax (Vermögensteuer);

including the supplements levied thereon;

b) in the Republic of Cameroon:

i. the tax on the income of individuals, including surcharges of the local authorities (centimes additionnels) and ii. the corporate income tax or the minimum corporate income tax, including surcharges of the local authorities (centimes additionnels).

1. The Convention shall apply also to any identical or substantially similar taxes that are imposed by one of the Contracting States after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their taxation laws.

# Article 3

# General definitions

1For the purposes of this Convention, unless the context otherwise requires:

a) the term "Federal Republic of Germany" means the territory of the Federal Republic of Germany, as well as the areas of the sea-bed, its subsoil and the superjacent water column adjacent to the territorial sea, insofar as the Federal Republic of Germany exercises there sovereign rights and jurisdiction in conformity with international law and its national legislation for the purpose of exploring, exploiting, conserving and managing the living and non-living natural resources; b) the term "Republic of Cameroon" means the territory of the Republic of Cameroon including the territorial sea and the areas outside the territorial waters of the Republic of Cameroon in which, the Republic of Cameroon, in accordance with international law, exercises there sovereign rights for the purposes of exploiting the natural resources of the seabed, the subsoil and superjacent water column;