COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • April 3rd, 2012
Contract Type FiledApril 3rd, 2012The Competent Authorities of the Federal Republic of Germany and the United States of America hereby enter into the following agreement (the “Agreement”) regarding the eligibility of certain pension arrangements for benefits under paragraph 3(b) of Article 10 (Dividends) of the Convention Between the United States of America and Germany for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital and to Certain Other Taxes, together with a related Protocol signed on August 29, 1989, and amended by the Protocol signed on June 1, 2006 (the “Treaty”). The Agreement is entered into under paragraph 3 of Article 25 (Mutual Agreement Procedure) of the Treaty.