Germany has confirmed completion of its internal procedures for the MLI, enabling its application to tax treaties with the Czech Republic and Japan from 1 January 2026.
Germany has deposited its notifications confirming the completion of internal procedures for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 1 June 2025. This applies to Germany’s covered tax treaties with the Czech Republic and Japan.
The notifications meet Germany’s reservation that the MLI requires a notification deposit before entering into force. This step is necessary for the MLI to take effect in relation to these agreements.
Following the deposit, the MLI provisions will apply to the covered agreements for taxable periods starting on or after 1 January 2026. This includes taxes withheld at source and other taxes under the treaties.
Earlier, the German Federal Council gave its approval for the Act on the Application of the Multilateral Agreement and Other Measures on 14 June 2024, 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.
