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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 VII

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

  1. Article 14 (Independent Personal Services) of the Convention shall be deleted and the

Articles following Article 14 shall not be re-numbered.

  1. Paragraph 3 of Article 11 (Interest) of the Convention shall be modified by deleting

the words “, or performs in that other State independent personal services from a fixed

base situated therein,”, "or fixed base", and “or Article 14 (Independent Personal

Services), as the case may be,” where they appear.

  1. Paragraph 5 of Article 11 of the Convention shall be modified by deleting the words

“or a fixed base” where they appear.

  1. Paragraph 3 of Article 12 (Royalties) of the Convention shall be modified by deleting

the words “, or performs in that other State independent personal services from a fixed

base situated therein,” and “or Article 14 (Independent Personal Services), as the case

may be,” where they appear.

  1. Paragraph 3 of Article 13 (Gains) of the Convention shall be modified by deleting the

words “or of movable property pertaining to a fixed base available to a resident of a

Contracting State in the other Contracting State for the purpose of performing

independent personal services” and "or of such fixed base" where they appear.

  1. Subparagraph c) of paragraph 2 of Article 15 (Dependent Personal Services) of the

Convention shall be modified by deleting the words “or a fixed base” where they appear.

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  1. Paragraph 1 of Article 17 (Artistes and Athletes) of the Convention shall be modified

by deleting the words “, 14 (Independent Personal Services)” where they appear.

  1. Paragraph 2 of Article 17 of the Convention shall be modified by deleting the words

“and 14 (Independent Personal Services),” where they appear.

  1. Paragraph 2 of Article 21 (Other Income) of the Convention shall be modified by

deleting the words “; or the recipient performs in that other State independent personal

services from a fixed base situated therein, and the income is attributable to the fixed

base” where they appear.

  1. Paragraph 2 of Article 22 (Capital) of the Convention shall be modified by deleting

the words “, or by movable property pertaining to a fixed base available to a resident of a

Contracting State in the other Contracting State for the purpose of performing

independent personal services,” where they appear.

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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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