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Us Germany Double Tax Agreement

o) Royalties and expenditures are borne equally by States Parties. As a general rule, the costs of the members of the arbitration body are set at the fixed amount of $2,000 (two thousand dollars) per day or the corresponding amount in euros, subject to the change made by the competent authorities. As a general rule, the expenses of the members of the arbitration body are determined in accordance with the International Centre for Settlement of Investment Disputes (ICSID) Schedule of Fees (as in effect on the day of the start of the arbitration), subject to the amendment made by the competent authorities. All language translation costs are also borne equally by the States Parties. The meeting bodies, the related resources, the financial management, logistical support and the general administrative coordination of the procedure are provided at its own expense by the State Party whose competent authority has initiated the procedure of mutual agreement. All other costs are borne by the State party in its care. The Double Taxation Convention or the Income Tax Convention between Germany and the United States of America came into force in 1990 and serves as an instrument to eliminate double taxation of the incomes of U.S. and German residents operating in both countries. The Double Taxation Convention between Germany and the United States also contains provisions to prevent tax evasion. The agreement is also an effective instrument for promoting economic cooperation between Germany and the United States and aims to encourage entrepreneurs to invest in contracting parties. 22.

With regard to Article 25, paragraphs 5 and 6 (mutual agreement procedure): in all cases where the competent authorities have tried but are unable to reach an agreement in accordance with Article 25, on the application of one or more of the following articles of the Convention: 4 (stay) (but only to the extent that it concerns the stay of a natural person) , 5 (permanent establishment), 7 (commercial profits), 9 (associated companies), 12 (fees), mandatory mores, is used to determine such a request, unless the competent authorities accept that the particular case is not appropriate for determination by arbitration. In addition, the competent authorities may agree ad hoc that a binding arbitration procedure applies to all other issues to which Article 25 applies. When an arbitration procedure begins in accordance with Article 25, paragraph 5, the following rules and procedures apply: Germany currently has double taxation agreements with the countries mentioned below: with regard to the taxation of dividends in Germany and the United States, the agreement provides that dividends paid by a company registered in one of the contracting states may be taxed in another state. However, the tax on dividends can also be collected in the country of origin of the company in case of double taxation. In this case, the contract provides that the tax is levied at a maximum tax rate of 5% of the gross amount of dividends if the beneficiary holds at least 10% of the voting rights in the company that distributes the dividends. In all other cases, the dividend tax is 15%. That is why many countries have so-called double taxation agreements. As the name suggests, these agreements are designed to avoid double taxation.

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