This treatment differs from that provided for in ArticleВ 10 of the convention for income from dividends, which are, in principle, taxed in the State of their source.ДЄrticleВ 11(2) of the Austro-German Convention provides: Under ArticleВ 11(1) of the Austro-German Convention, income in the form of interest is taxed in the State of residence or establishment of the beneficial owner. вЂAs regards the application of the at any time by a Contracting State, any term or phrase not defined therein shall, unless the context requires a different interpretation, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Convention applies, the meaning of that term or phrase according to the tax law of that State having priority over its meaning according to other fields of law of that State.вЂ™ вЂA treaty shall be interpreted in good faith in accordance with the ordinary meaning to be given to the terms of the treaty in their context and in the light of its object and purpose.вЂ™ДЄrticleВ 3(2) of the Austro-German Convention provides: III, 182/2002, вЂthe Austro-German ConventionвЂ™) concerning the taxation of the interest from financial instruments ( Genussscheine) issued by a company with its seat in the Federal Republic of Germany and held by a company with its seat in the Republic of Austria.ДЄrticleВ 31(1) of the Vienna Convention on the Law of Treaties of 23В May 1969 (United Nations Treaty Series, vol.В 1155, p.В 331) (вЂthe Vienna ConventionвЂ™) reads as follows:

Having regard to the written procedure and further to the hearing on 6В December 2016,ДЄfter hearing the Opinion of the Advocate General at the sitting on 27В April 2017,Д«y its application, the Republic of Austria asks the Court to rule on the dispute which has arisen between it and the Federal Republic of Germany concerning the interpretation of ArticleВ 11(2) of the Abkommen zwischen der Republik Г–sterreich und der Bundesrepublik Deutschland zur Vermeidung der Doppelbesteuerung auf dem Gebiet der Steuern vom Einkommen und vom VermГ¶gen (Convention between the Republic of Austria and the Federal Republic of Germany for the avoidance of double taxation with respect to taxes on income andВ capital) of 24В August 2000 (BGBl. Republic of Austria, represented by C.В Pesendorfer, F.В Koppensteiner and H.В Jirousek, acting as Agents,ДЇederal Republic of Germany, represented by T.В Henze and J.В MГ¶ller, acting as Agents,Д¬omposed of K.В Lenaerts, President, A.В Tizzano, Vice-President, R.В Silva de Lapuerta, T.В von Danwitz and J.L.В da Cruz VilaГ§a, Presidents of Chambers, J.В MalenovskГЅ, E.В Levits, J.-C.В Bonichot (Rapporteur), A.В Arabadjiev, C.В Toader, C.G.В Fernlund, C.В Vajda, S.В Rodin, F.В Biltgen and K.В JГјrimГ¤e, Judges, (ArticleВ 273 TFEUВ - Dispute between Member States submitted to the Court under a special agreement between the partiesВ - TaxationВ - Bilateral convention for the avoidance of double taxationВ - Taxation of interest from financial instrumentsВ - Definition of вЂdebt-claims with participation in profitsвЂ™)ДЄPPLICATION pursuant to ArticleВ 273 TFEU, lodged on 3В December 2015, Republic of Austria v Federal Republic of Germany.ДЄrticle 273 TFEU - Dispute between Member States submitted to the Court under a special agreement between the parties - Taxation - Bilateral convention for the avoidance of double taxation - Taxation of interest from financial instruments - Definition of вЂdebt-claims with participation in profitsвЂ™. Judgment of the Court (Grand Chamber) of 12 September 2017. Judgment of the Court (Grand Chamber) of 12 September 2017.#Republic of Austria v Federal Republic of Germany.#Article 273 TFEU - Dispute between Member States submitted to the Court under a special agreement between the parties - Taxation - Bilateral convention for the avoidance of double taxation - Taxation of interest from financial instruments - Definition of вЂdebt-claims with participation in profitsвЂ™.#Case C-648/15.

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