Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Federal Republic of Germany : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-18-90

Cover Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Federal Republic of Germany : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-18-90
Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Federal Republic of Germany : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-18-90
United States. Congress. Joint Committee On Taxation
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tax. To pre- vent third-country residents from obtaining treaty benefits intend- ed for treaty country residents only, the treaties generally contain an "anti-treaty shopping" provision that is designed to limit treaty benefits to bona fide residents of the two countries.
The treaties generally provide that neither country may subject nationals of the other country (or permanent establishments of en- terprises of the other country) to taxation more burdensome than that it imposes on its own nat
...ionals (or on its own enterprises).
Similarly, in general, neither country may discriminate against en- terprises owned by residents of the other country.
IV. EXPLANATION OF PROPOSED TAX TREATY A detailed article-by-article explanation of the proposed income tax treaty between the United States and Germany is presented below. This explanation includes a discussion of the proposed proto- col under the treaty articles amended by it. Also presented below are explanations of the notes exchanged when the proposed treaty was signed.


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