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 4 (Residence) of the Convention is amended by deleting paragraph 1 and

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

substituting the following paragraph:

“1. For the purposes of this Convention, the term "resident of a Contracting State"

means any person who, under the laws of that State, is liable to tax therein by

reason of his domicile, residence, place of management, place of incorporation, or

any other criterion of a similar nature, and also includes that State and any political

subdivision or local authority thereof. The term, however, does not include any

person who is liable to tax in that State in respect only of income from sources in

that State or of profits attributable to a permanent establishment in that State or

capital situated therein.”

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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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