The US Internal Revenue Service (IRS) has published guidance regarding the mandatory arbitration procedure contained in the 2006 protocol to the UnitedStates-Germany tax treaty that entered into force on 28 December 2007. The guidance is contained in IRS Announcement 2008-39.
The 2006 protocol modified certain provisions of the tax treaty. Among other modifications, the protocol revises the mutual agreement procedure (MAP) in Art. 25 of the treaty to provide for …