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ARTICLE 22

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

Capital

  1. Capital represented by immovable property referred to in Article 6 (Income from Immovable (Real) Property), owned by a resident of a Contracting State, and situated in the other Contracting State may be taxed in that other State.

  2. Capital represented by immovable property forming part of the business property of a permanent establishment that an enterprise of a Contracting State has in the other Contracting State, or by immovable 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, may be taxed in that other State.

  3. Capital represented by ships, aircraft, or containers operated in international traffic and by immovable property pertaining to the operation of such ships, aircraft, or containers shall be taxable only in the Contracting State in which the profits of the enterprise owning such capital are taxable according to Article 8 (Shipping and Air Transport).

  4. All other elements of capital of a resident of a Contacting State shall be taxable only in that State.

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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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