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Protocol Amending the Convention between The United States of America and The � Federal Republic of Germany for the Avoidance of Double Taxation and the � Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital and to � Certain Other Taxes Please note that the text of this Convention starts two-thirds of the way down this � page. The page layout of this file reflects the layout of the original signed treaty � document. This document is designed to print on 8 by 14 legal size or

Article 1 (Personal Scope) of the Convention is deleted and the following Article

U.S. Income Tax Treaty — germany tax treaty documents: germanprot06.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

substituted:

“Article 1 General Scope

  1. This Convention shall apply to persons who are residents of one or both of the

Contracting States, except as otherwise provided in this Convention.

  1. This Convention shall not restrict in any manner any exclusion, exemption, deduction,

credit, or other allowance now or hereafter accorded:

a) by the laws of either Contracting State; or

b) by any other agreement to which the Contracting States are party.

a) Notwithstanding the provisions of subparagraph b) of paragraph 2:

aa) the Contracting States agree that any question arising as to the interpretation or

application of the Convention and, in particular, whether a taxation measure is

within the scope of the Convention, shall be determined exclusively in accordance

with the provisions of Article 25 (Mutual Agreement Procedure) of the

Convention; and

bb) the provisions of any other agreement shall not apply to a taxation measure unless

the competent authorities agree that the measure is not within the scope of Article 24

(Nondiscrimination) of this Convention.

b) For the purposes of this paragraph, a “measure” is a law, regulation, rule, procedure,

decision, administrative action, or any similar provision or action.

a) Except to the extent provided in paragraph 5, this Convention shall not affect the

taxation by the United States of its residents (as determined under Article 4

(Residence)) and its citizens.

b) Notwithstanding the other provisions of this Convention, a former citizen or long-term

resident of the United States may, for the period of ten years following the loss of such

status, be taxed in accordance with the laws of the United States.

3

  1. The provisions of paragraph 4 shall not affect the benefits conferred by the United

States:

a) under paragraph 2 of Article 9 (Associated Enterprises), paragraph 6 of Article 13

(Gains), paragraphs 3, 4 and 5 of Article 18 (Pensions, Annuities, Alimony, Child

Support, and Social Security), paragraph 1 and 5 of Article 18A (Pension Plans),

paragraph 3 of Article 19 (Government Service), and under Articles 23 (Relief from

Double Taxation), 24 (Nondiscrimination), and 25 (Mutual Agreement Procedure);

and

b) under paragraph 2 of Article18A (Pension Plans), subparagraph b) of paragraph 1 of

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▸Contents — U.S. Income Tax Treaty — germany tax treaty documents: germanprot06.pdf
U.S. Income Tax Treaty — germany tax treaty documents: germanprot06.pdf

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