The German Federal Council approved an expansion of the scope of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 8 May 2026. This move represents a major step in Germany’s commitment to the OECD/G20 BEPS Project.
The German Federal Council approved the Act Amending the Act on the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), expanding the scope of covered agreements (tax treaties) for the purposes of the MLI on 8 May 2026.
Germany originally designated 14 tax treaties as covered agreements under the MLI. The MLI, adopted in 2016 as part of the OECD/G20 BEPS Project, aims to combat harmful tax practices and aggressive tax planning through coordinated changes to bilateral tax treaties. Germany implements the MLI in two steps: first by passing an enabling act, and then by adopting a separate application act.
The legislation enacted on 22 November 2020 applied the MLI to the initial 14 treaties. The new bill extends the MLI’s application to 62 additional tax treaties that have not yet met the BEPS minimum standard. The selection criteria and reservations set out in the 2020 legislation will generally continue to apply to these additional treaties.
Earlier, the German Ministry of Finance released a draft bill titled Act Amending the Act on the Multilateral Convention of 24 November 2016 to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI) on 9 October 2025, intending to expand the list of tax treaties covered by the BEPS MLI.
