On 27 November 2020, Germany published the law in the Official Gazette to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Germany must now deposit its ratification instrument in order to put the MLI into force for its covered agreements (tax agreements).
The ratification process will be completed when the President signs the relevant legislation and it has been published in the gazette. Germany can then deposit its instrument of ratification to bring the measures into force. The provisions of the MLI would normally enter into force in relation to the amendments to a tax treaty from the first day of the month after a period of three months from the date that both parties to the agreement have deposited their instruments of ratification.
With regard to the effective date for amended agreements, Germany has opted for a reservation under the MLI that provides for an amended tax treaty to become effective only after it has deposited a relevant notification that its internal procedures have been completed to allow the entry into effect of the MLI for a specific covered agreement.
