Double Taxation Agreement Germany Usa 2008

5. If the competent authorities have endeavoured, in the context of a mutual agreement procedure under this Article, but are unable to reach full agreement in a case, the matter shall be settled by arbitration conducted in accordance with the provisions of paragraph 6 below and subject to the requirements of paragraph 6 and the rules or procedures agreed upon by the States Parties; If: 7. In the case of income, profit or profit realized by or by a person which, under the law of a Contracting State, is fiscally transparent, that item shall be derived from property established in a State, to the extent that the item is treated as income for the purposes of the tax laws of that State; Profit or benefit of a resident. On this page you will find information on German double taxation conventions and other country-by-country publications on double taxation conventions. The original texts can be viewed via our German website. 1. The competent authorities of the States Parties shall exchange the information necessary for the application of the provisions of this Convention and the domestic law of the Contracting States concerning the fees covered by this Convention, to the extent that the taxation of this Convention is not contrary to this Convention. The exchange of information is not limited by Article 1 (Personal scope).