The key changes in the guidance are aimed at simplifying terminology, clarifying the interaction of dispute resolution mechanisms, and providing expanded guidance for joint applications from partnerships and corporate groups.
Germany’s Ministry of Finance (MOF) issued an updated version of its guidance on international mutual agreement and arbitration procedures for income and capital taxes on 24 September 2025.
Key changes include the elimination of outdated terminology, clearer explanations of how different dispute resolution mechanisms interact, and expanded instructions for submitting joint applications from partnerships and corporate groups.
The update incorporated recent legal changes and sought to increase transparency for taxpayers engaged in cross-border disputes.
International dispute resolution procedures are intergovernmental procedures initiated at the request of one or more taxpayers to achieve consistent application of a DTA or the EU Arbitration Convention. This memorandum does not cover those procedures under DTAs for which taxpayers have no right to submit an application (particularly Art. 24(3) of the Model Convention).
The guidance also integrates references to Germany’s adoption of the OECD’s BEPS Multilateral Instrument and emphasises the application of the EU Directive on Tax Dispute Resolution. The updates are intended to enhance legal certainty, align domestic procedures with international standards, and facilitate more efficient resolution of cases involving double taxation.
Earlier, Germany signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) on 19 September 2025, as part of Pillar 2 of the OECD/G20 Inclusive Framework on the Two-Pillar Solution.
