The United States has entered into new treaties and protocols with Belgium, Canada and Germany to allow for a mandatory arbitration process to supplement the historic negotiation process used in the Mutual Agreement Procedure. Documents relating to this process may be accessed through the links established below.
Germany
A new Protocol modifying certain provisions of the income tax treaty between the United States of America (U.S.) and the Federal Republic of Germany (Germany) came into force on December 28, 2007. Among other things, the Protocol modifies Article 25 (Mutual Agreement Procedure) to provide for mandatory arbitration of certain cases in the mutual agreement procedure (MAP).
The competent authorities of the U.S. and Germany recently signed an arrangement regarding the application of the arbitration procedure. The purpose of the arrangement is to provide guidance under which the U.S.- German arbitration procedure will operate. In addition to the arrangement,