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Do S Corporations Have Rights to Germany-U.S. Treaty Benefits?

U.S. corporations have the option of being taxed like partnerships. Also, those corporations often hold shares in German companies. In those cases, the German Federal Tax Office denies U.S. corporations the reduced withholding tax rate for dividends on substantial shareholdings according to the Germany-U.S. tax treaty. That view was recently supported by the Tax Court of Cologne, which has competence at first instance to hear all claims against the German Federal Tax Office throughout Germany. The court went further and held that those corporations were not entitled to any benefits under the treaty. However, the judgment is not convincing.