Germany signed the GIR MCAA on 19 September 2025, joining 17 jurisdictions under Pillar 2 of the OECD/G20 framework.
Germany signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) on 19 September 2025, as part of Pillar Two of the OECD/G20 Inclusive Framework on the Two-Pillar Solution.
The Global Anti-Base Erosion (GloBE) Model Rules require each Constituent Entity of an MNE Group to annually file a GloBE Information Return (GIR) with the tax administration of the jurisdiction where it is located to support the administration of the GloBE Rules.
The GIR is a standardised return and consists of two parts, namely a General Section that provides general information about the MNE Group as a whole, including its corporate structure and a high-level overview of the application of the GloBE Rules to the MNE Group, as well as one or more Jurisdictional Sections reflecting the detailed application of the GloBE Rules and the QDMTT, where applicable, in respect of each jurisdiction where the MNE Group operates.
The portions of the GIR to be provided to each jurisdiction where the MNE Group is operating are multilaterally agreed as part of the Dissemination Approach and depend on the MNE Group’s structure and the rule order under the GloBE Rules.
At the time of writing, a total of 17 jurisdictions have signed the GIR MCAA.
