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 7 (Business Profits) 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) deleting paragraph 3 and substituting the following paragraph:

“3. In determining the business profits of a permanent establishment, there shall be

allowed as deductions expenses that are incurred for the purposes of the permanent

establishment, including executive and general administrative expenses so incurred,

whether in the State in which the permanent establishment is situated or elsewhere.”; and

b) in paragraph 7, adding the words “and income from the performance of professional

services and of other activities of an independent character”.

Get a plain-English answer with a citation back to this text.

Ask AI about this code

Export this section

▸Contents — U.S. Income Tax Treaty — germany tax treaty documents: germanprot06.pdf

U.S. Income Tax Treaty — germany tax treaty documents: germanprot06.pdf

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.