On 14 June 2024, the German Federal Council gave its approval for the Act on the Application of the Multilateral Agreement and Other Measures, which the Bundestag approved on 16 May 2024. This Act facilitates the implementation of the Multilateral Convention to Prevent Base Erosion and Profit Shifting (BEPS MLI) to Germany’s tax treaties.
The Act mandates the preparation of notifications for the application of the BEPS MLI to Germany’s covered agreements, including those with Croatia, Czech Republic, Greece, France, Malta, Hungary, Spain, Slovak Republic, and Japan.
The Act excludes treaties with Austria and Luxembourg, which have already been amended bilaterally, and treaties with Italy and Turkey, as these countries didn’t deposit their ratification instruments. Romania has also been excluded from the Act because it didn’t incorporate its MLI ratification instrument with its treaty with Germany.
