Changes to the Germany-United States double-taxation treaty

Dr Ingmar Dörr and Mitchell B Weiss

The protocol amending the Germany–United States double-taxation treaty entered into force on 28 December 2007. The most significant changes include a full exemption from withholding tax on certain dividends, a tightening of the limitation on benefits provisions, the imposition of mandatory binding arbitration procedures and the modernisation of the provisions governing pension plans. Ingmar Dörr and Mitch Weiss provide a brief overview of the changes to the Germany–United States double-taxation treaty.