Germany: Legislation to expand MLI to 62 additional treaties passed by lower house of Parliament; other tax developments
Draft laws implementing DAC9 and CARF, draft ordinance amending Pillar Two reporting
The lower house of Parliament (Bundestag) on March 26, 2026, passed legislation to amend the MLI Implementation Amendment Act of November 24, 2016, to expand the list of “covered tax treaties” to include 62 additional income tax treaties (including treaties with significant trading partners and members of the G20, such as the United States, China, Poland, Belgium, Portugal, South Korea, India, Canada, Argentina, and Indonesia).
The original act from November 22, 2020, covered 14 treaties. The selection decisions made by Germany in the original act are largely replicated for the newly covered treaties.
The legislative process is expected to be completed before the parliamentary summer recess, pending approval from the upper house of Parliament (Bundesrat).
Other recent tax developments in Germany include:
- Draft law on automatic exchange of minimum tax reports (DAC9)
- Draft ordinance amending minimum tax reporting ordinance
- Draft law on exchange of information with third countries on platform revenues
- Draft law implementing cryptoasset reporting framework (CARF)
- Federal Tax Court (I R 41/22): Disclosure of hidden reserves possible due to entry into force of new income tax treaty
- Draft general administrative regulation for tax audits
- General Decree of the German Federal Central Tax Office: Revocation of the so-called MURI-report in old cases
Read a May 2026 report prepared by the KPMG member firm in Germany