OrbitaxProtocol to treaty between US and Germany – IRS issues interim guidance re mandatory arbitration procedure
|Treaty Development|United States-Germany
The US Internal Revenue Service (IRS) has published guidance regarding the mandatory arbitration procedure contained in the 2006 protocol to the UnitedStates-Germany tax treaty that entered into force on 28 December 2007. The guidance is contained in IRS Announcement 2008-39.
The 2006 protocol modified certain provisions of the tax treaty. Among other modifications,…
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