US-German Competent Authority Agreement addresses characterization of foreign pension fund

US Tax Treaty Developments

The Competent Authorities of the United States and Germany have agreed not to tax dividends from investments made by certain US or German pension funds. As discussed in the newsalert, the agreement clarifies the term "pension fund". Under the agreement, dividends derived by specifically identified entities are eligible for an exemption from tax withheld at source as if the entity is the beneficial owner of the dividends.

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