Germany updates tax treaty overview for 2026, highlighting ongoing negotiations, new agreements, and disruptions in key jurisdictions.

RF Report

The German Federal Ministry of Finance has released its latest overview of tax treaties and related agreements, providing a snapshot of the country’s international tax relations as of 1 January 2026.

The report details ongoing negotiations, concluded amendments, and newly initialed treaties, reflecting Germany’s efforts to modernise its network of double taxation agreements (DTAs) in line with international standards, including the BEPS Multilateral Instrument.

Key Updates:

  • Ongoing Negotiations: Amendments to tax treaties with France and Italy are still under discussion.
  • Concluded Negotiations: Amending protocols with Albania, Kuwait, Kyrgyzstan, New Zealand, and Slovenia have been concluded.
  • New Treaties: New agreements will replace existing treaties with Belgium, Kosovo, Moldova, Montenegro, Serbia, and Ukraine.

The report also notes disruptions in certain jurisdictions, including:

  • Russia: Unilateral suspension of selected treaty provisions.
  • Belarus: Complete termination of the existing tax treaty.

Administrative guidance is provided for provisional tax assessments where new agreements have been signed but not yet ratified. The overview further clarifies rules for legal succession in the context of historical state changes, including those related to the former Soviet Union and Yugoslavia.

Summary Table of Treaty Status (Selected Countries)

Country Status as of 1 Jan 2026 Notes
France Negotiations ongoing Amending Protocol under discussion
Italy Negotiations ongoing Amending Protocol under discussion
Albania Protocol initialed Negotiations concluded
Kuwait Protocol initialed Negotiations concluded
Kyrgyzstan Protocol initialed Negotiations concluded
New Zealand Protocol initialed Negotiations concluded
Slovenia Protocol initialed Negotiations concluded
Belgium New treaty initialed Replaces existing treaty
Kosovo New treaty initialed Replaces existing treaty
Moldova New treaty initialed Replaces existing treaty
Montenegro New treaty initialed Replaces existing treaty
Serbia New treaty initialed Replaces existing treaty
Ukraine New treaty initialed Replaces existing treaty
Russia Partial suspension of treaty provisions Unilateral action
Belarus Treaty terminated Complete termination