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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 19 (Government Service), and under Articles 20 (Visiting Professors and

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

Teachers; Students and Trainees) and 30 (Members of Diplomatic Missions and

Consular Posts), upon individuals who are neither citizens of, nor have immigrant

status in, the United States.

  1. Nothing in the Convention shall be construed to prevent the Federal Republic of

Germany from imposing its taxes on amounts included in the income of a resident of the

Federal Republic of Germany according to part 4, 5, and 7 of the German

"Außensteuergesetz". Where such imposition of tax gives rise to double taxation, the

competent authorities shall consult for the elimination of such double taxation according

to paragraph 3 of Article 25 (Mutual Agreement Procedure).

  1. In the case of an item of income, profit or gain derived by or through a person that is

fiscally transparent under the laws of either Contracting State, such item shall be

considered to be derived by a resident of a State to the extent that the item is treated for

the purposes of the taxation law of such State as the income, profit or gain of a resident.”

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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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