The Federal Government has published the 2026 update to its basis for negotiating Double Taxation Agreements (DTAs), incorporating changes from the 2017 OECD Model Tax Convention, outcomes of the G20/OECD Base Erosion and Profit Shifting (BEPS) Project, and amendments to Germany's domestic tax legislation.
Germany has published the 2026 update to its basis for negotiating Double Taxation Agreements (DTAs) covering taxes on income and on capital. The document serves as the Federal Government’s starting point for treaty negotiations with foreign states and is available in both German and English.
Germany’s treaty network for taxes on income and on capital currently includes DTAs with more than 90 countries. While the OECD and United Nations Model Tax Conventions influence treaty drafting, each DTA is negotiated individually between two contracting states through an extensive negotiation process.
The 2026 update incorporates changes introduced in the 2017 OECD Model Tax Convention compared with the version of the negotiation basis published in 2013. According to the Federal Government, these revisions are largely based on the outcomes of the G20/OECD Base Erosion and Profit Shifting (BEPS) Project and introduce additional safeguards against unfair tax competition and aggressive tax planning. The document has also been revised to reflect changes in Germany’s domestic tax legislation.
The Federal Government said the basis for negotiation is intended to provide a framework rather than a fixed model for treaty discussions. It noted that negotiations require a balanced assessment of bilateral economic relations, taking into account Germany’s competitiveness as a business location, the overseas activities of export-oriented German companies, and the protection of Germany’s taxing rights. Differences in domestic law and the treaty policy of the other contracting state mean that the form and content of DTA provisions may vary depending on the circumstances of each negotiation.
This announcement was on 3 July 2026.
