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ARTICLE 21

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

Other Income

  1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.

  2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6 (Income from Immovable (Real) Property), if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, and the right or property in respect of which the income is paid from part of the business property of the permanent establishment; 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.

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

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