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ARTICLE 27

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

Exempt Organizations

  1. Notwithstanding the provisions of Article 28 (Limitation on Benefits), a German company or organization operated exclusively for religious, charitable, scientific. educational, or public purposes shall be exempt from tax by the United States in respect of items of income, if and to the extent that

a) such company or organization is exempt from tax in the Federal Republic of Germany, and

b) such company or organization would be exempt from tax in the United States in respect of such items of income if it were organized, and carried on all its activities, in the United States.

  1. Notwithstanding the provisions of Article 28 (Limitation on Benefits), a United States company or organization operated exclusively for religious, charitable, scientific, educational, or public purposes shall be exempt from tax by the Federal Republic of Germany in respect of items of income if and to the extent that

a) such company or organization is exempt from tax in the United States, and

b) such company or organization would be exempt from tax in the Federal Republic of Germany in respect of such items of income if it were a German company or organization and carried on all its activities in the Federal Republic of Germany.

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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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