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 11 (Interest) of the Convention is modified by:

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

a) inserting the following new paragraph 6:

“6. Notwithstanding the provisions of paragraph 1, interest that is an excess inclusion

with respect to a residual interest in a U.S. real estate mortgage investment conduit may

be taxed by the United States in accordance with its domestic law.”; and

b) in paragraph 5, deleting the words “paragraph 8 (a)(bb)” where they appear and

substituting the words “subparagraph b) of paragraph 9”.

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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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