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Mandatory Arbitration with Germany, Belgium, Canada, and France

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,

U.S./Germany Tax Treaty Modified to Include Mandatory Arbitration in Certain Circumstances

Arbitration Board Operating Guidelines

Memorandum of Understanding between the U.S. and Germany

Germany -- Tax Treaty Documents

Competent Authority Agreements

 

Belgium

U.S./Belgium Tax Treaty Modified to Include Mandatory Arbitration in Certain Circumstances

Belgium - Tax Treaty Documents

Competent Authority Agreements

Memorandum of Understanding between the U.S. and Belgium

Arbitration Board Operating Guidelines

 

Canada

Memorandum of Understanding Between the Competent Authorities of Canada and The United States of America

Arbitration Board Operating Guidelines

Canada – Tax Treaty Documents

Competent Authority Agreements

 

France

United States - France Competent Authority Memorandum of Understanding

United States - France Arbitration Board Operating Guidelines

U.S./France Tax Treaty Protocol (2009) to Include Mandatory Arbitration in Certain Circumstances

U.S./France Memorandum of Understanding accompanying 2009 Protocol

U.S. Technical Explanation to 2009 U.S./France Protocol

Page Last Reviewed or Updated: 06-Nov-2013