This document provides a copy of the Memorandum of Understanding Between the Competent Authorities of the Federal Republic of Germany and the United States of America regarding the arbitration process set forth in the United States-Germany Income Tax Convention.

This document provides guidelines regarding the arbitration process set forth in the United States-Germany Income Tax Convention as amended by the Protocol signed on June 1, 2006. These guidelines relate to the Memorandum of Understanding Between the Competent Authorities of the Federal Republic of Germany and the United States of America signed on December 8, 2008.