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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; Social Security) of the Convention is deleted and the

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

following Article substituted:

“Article 19 Government Service

  1. Notwithstanding the provisions of Articles 15 (Dependent Personal Services), 16

(Directors’ Fees) , and 17 (Artistes and Athletes):

a) salaries, wages and other similar remuneration, other than a pension, paid by a

Contracting State or a political subdivision, local authority or an instrumentality

thereof to an individual in respect of services rendered to that Contracting State or a

political subdivision, local authority or an instrumentality thereof shall, subject to

the provisions of subparagraph b), be taxable only in that State;

b) such remuneration, however, shall be taxable only in the other Contracting State if

the services are rendered in that State and the individual is a resident of that State

who:

aa) is a national of that State; or

bb) did not become a resident of that State solely for the purpose of rendering the

services.

  1. a) Notwithstanding the provisions of paragraph 1, pensions and other similar

remuneration paid by, or out of funds created by, a Contracting State or a political

subdivision, local authority or an instrumentality thereof to an individual in respect

of services rendered to that State or subdivision, authority or instrumentality shall

be taxable only in that State.

b) However, such pensions and other remuneration shall be taxable only in the

other Contracting State if the individual is a

aa) resident of, and a national of, that State; or

bb) the pension is not subject to tax in the Contracting State for which the services

were performed because the services were performed entirely in the other

Contracting State.

14

  1. Pensions, annuities, and other amounts paid by one of the Contracting States or by a

juridical person organized under the public laws of that State as compensation for an

injury or damage sustained as a result of hostilities or political persecution shall be

exempt from tax by the other State.

  1. The provisions of Articles 15 (Dependent Personal Services), 16 (Directors’ Fees), 17

(Artistes and Athletes), and 18 (Pensions, Annuities, Alimony, Child Support, and Social

Security) shall apply to salaries, wages and other similar remuneration, and to pensions,

in respect of services rendered in connection with a business carried on by a Contracting

State or by a political subdivision, local authority or an instrumentality thereof.

  1. In this Article, the term "instrumentality" means any agent or entity created or

organized by a Contracting State, one of its states or a political subdivision or local

authority thereof in order to carry out functions of a governmental nature which is

specified and agreed to in letters exchanged between the competent authorities of the

Contracting States.”

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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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