The German Ministry of Finance has released a draft bill to implement the Multilateral Competent Authority Agreement on the Exchange of GloBE Information Returns (GIR MCAA), enabling streamlined global minimum tax reporting for multinational enterprises.
The German Ministry of Finance (MOF) on 20 March 2026 published a draft bill to implement the Multilateral Competent Authority Agreement on the Exchange of Global Anti-Base Erosion (GloBE) Information Returns (GIR MCAA), which Germany signed on 19 September 2025.
The law is expected to enter into force the day after promulgation.
The GIR MCAA forms part of the OECD/G20 “Two-Pillar Solution,” addressing tax challenges in the digitalized economy under Pillar Two, which establishes a 15% global minimum tax for multinational enterprise (MNE) groups with annual revenues above EUR 750 million.
The agreement allows MNE groups to file a single GloBE Information Return (GIR) centrally with the tax authority of their Ultimate Parent Entity (UPE) or a Designated Filing Entity. Relevant sections of the return are then automatically shared with tax authorities in other jurisdictions where the group operates.
Under the draft law:
- Centralised filing: MNE groups can submit a single GloBE Information Return (GIR) to the tax authority of their Ultimate Parent Entity or a designated filing entity, reducing the need to file separately in each jurisdiction.
- Automatic exchange: The receiving authority shares relevant data automatically with other affected jurisdictions through secure systems.
- Reciprocity: Germany will exchange GIRs from German-headed MNEs with foreign partners and receive reports from foreign MNEs operating in Germany.
The GIR comprises a General Section summarising the MNE group and high-level GloBE data, and Jurisdictional Sections detailing compliance with GloBE rules and any Qualified Domestic Minimum Top-up Taxes (QDMTT). Reports are exchanged within three months of the filing deadline, extended to six months for the first reporting year. Data is transmitted using a common XML schema through the OECD Common Transmission System under strict encryption, with confidentiality safeguarded by the Convention on Mutual Administrative Assistance in Tax Matters.
The initial signatories include Germany, Belgium, France, the UK, Japan, and Ireland, with plans to expand to other jurisdictions meeting legal and data protection standards. The draft law clarifies that the agreement does not create additional compliance costs beyond those in the 2023 Minimum Tax Act and provides German MNEs legal certainty that a single filing satisfies global reporting obligations where active exchange relationships exist. The agreement also allows authorities to coordinate on corrections to ensure accuracy in risk management and tax assessments.
Earlier, Germany’s Ministry of Finance published a draft ordinance setting out the rules for filing and exchanging the GloBE Information Return (GIR) on 29 September 2025.
