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Germany – United States · Source editionArticle 22 Capital

Unreviewed · applicability unverified

(1)

1. Capital represented by immovable property referred to in Article 6 (Income from Immovable (Real) Property), owned by a resident of a Contracting State, and situated in the other Contracting State may be taxed in that other State.

PDF page · 18

(2)

2. Capital represented by movable property forming part of the business property of a permanent establishment that an enterprise of a Contracting State has in the other Contracting State may be taxed in that other State.

PDF page · 18

(3)

3. Capital represented by ships, aircraft, or containers operated in international traffic and by movable property pertaining to the operation of such ships, aircraft, or containers shall be taxable only in the Contracting State in which the profits of the enterprise owning such capital are taxable according to Article 8 (Shipping and Air Transport).

PDF page · 18PDF page · 19

(4)

4. All other elements of capital of a resident of a Contracting State shall by taxable only in that State.

PDF page · 19
Source, edition and limits
Source edition
BGBl. 2008 II S. 611 | Included protocol entered 2007-12-28 (original publication footnote, PDF31); publication 2008-06-23; correction851 unresolved | Signed: 1989-08-29 | Gazette publication: 2008-06-23
Source form
Original official-publication PDF with native text layer; unreviewed language-separated machine transcription of that exact publication
Source scope
Exact officially published consolidation, not a privately synthesized or certified current-law text
Retrieved
2026-09-30
Text and language scope
UNREVIEWED ORIGINAL 611-PUBLICATION ONLY. Correction BGBl.2008 II S.851 is identified but its wording/incorporation is unresolved. NOT a corrected final version or current law. Printed line breaks, hyphens and PDF word spacing retained. Article14 deletion marker and Article18A conserved. Separate preamble, protocol and publication footnotes: /review/de-united-states-2008-consolidated/. No consolidation closing or signatories invented. Page references are not verified paragraph alignment.
Review status
Pending qualified human review; no wording, completeness, legal alignment or indexing approval.
Currentness
Original source edition; not a verified current-law consolidation. No current-law determination, qualified human wording/completeness review, legal alignment, or indexing approval. No exhaustive later-development check. Page links identify source pages, not verified paragraph correspondence. Original 611 publication only; Correction851 unresolved. No corrected-final-version or full-language accuracy claim. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Includes protocol signed 2006-06-01, entry 2007-12-28 (publication footnote4, PDF31). Separate official correction BGBl.2008 II S.851 is linked in retained BMF metadata; its wording and incorporation remain unresolved. No correction applied. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2008 II S. 611
SHA-256
c712844fbd49d928461286efcca93ac57da6ead9def96d0efea940d3ad2333fd

Citation

Copyable citation

BGBl. 2008 II S. 611 | de-united-states-2008-consolidated | BGBl. 2008 II S. 611 | Included protocol entered 2007-12-28 (original publication footnote, PDF31); publication 2008-06-23; correction851 unresolved | Signed: 1989-08-29 | Gazette publication: 2008-06-23 | Article 22 | en | Pending qualified human review; no wording, completeness, legal alignment or indexing approval. | /library/treaties/de-united-states-2008-consolidated/en/articles/article-22/

Disclaimers

Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.

BGBl. 2008 II S. 611

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

Source-page links are references, not human paragraph verification.

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