Memorandum of Understanding signed between US and German competent authorities

The US Internal Revenue Service (IRS) has released the text of a signed Memorandum of Understanding (MOU) as well as a set of operating guidelines relating to the mandatory binding arbitration provisions contained in Article 25 (Mutual Agreement Procedure) of the US-Germany Income Tax Treaty as amended by the protocol signed on 1 June 2006. For a prior report on the arbitration procedure.The MOU was signed 8 December 2008. Together, the MOU and the operating guidelines set out the structure and…