Article 27 is essentially the same as Article XV A of the 1954 Convention. The Article

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

provides that a company or organization in one Contracting State which is operated exclusively for religious, charitable, scientific, educational or public purposes will be exempt from tax in the other Contracting State in respect of items of income if two conditions are met. The two conditions are

(1) that the company or organization be exempt from tax in its State of residence, and (2) that the company or organization would be exempt from tax on such items of income in the other Contracting State, under its laws, if the company or organization were organized in that other State and carried on all of its activities there.

None of the benefits of this Article can be denied by the application of the provisions of Article 28 (Limitation on Benefits). Paragraph 27 of the Protocol provides that the competent authorities will develop procedures to implement the Article.

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

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

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