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Memorandum of Understanding signed between US and German competent authorities

22 February 2009

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Treaty Development

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United States-Germany

The US Internal Revenue Service (IRS) has released the text of a signed Memorandum of Understanding (MOU) as well as a set of operating guidelines relating to the mandatory binding arbitration provisions contained in Article 25 (Mutual Agreement Procedure) of the US-Germany Income Tax Treaty as amended by the protocol signed on 1 June 2006. For a prior report on the arbitration procedure.The MOU was signed 8 December 2008. Together, the MOU and the operating guidelines set out the structure and organization of the new manditory binding arbitration board. Full electronic copies of the texts are available from the IRS...