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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 28, provided that the company satisfies the conditions described in

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

paragraph 4 of that Article with respect to an item of income, profit or gain

described in paragraph 9 of this Article;

c) is entitled under paragraph 3 of Article 28 to benefits with respect to an item of

income, profit or gain described in paragraph 9 of this Article; or

d) has received a determination pursuant to paragraph 7 of Article 28 with respect to

this paragraph.

  1. The term "pension fund" as used in this Article means any person that:

a) is established under the laws of a Contracting State;

b) is established and maintained in that Contracting State primarily to administer or

provide pensions or other similar remuneration, including social security payments,

disability pensions and widow’s pensions or to earn income for the benefit of one

or more of such persons; and

c) is either,

aa) in the case of the United States, exempt from tax in the United States with

respect to the activities described in subparagraphb) of this paragraph, or

bb) in the case of the Federal Republic of Germany, a plan the contributions to

which are eligible for preferential treatment under the Income Tax Act.”

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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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