Global Daily Tax News, German Lawmakers Agree BEPS Provisions For 62 More Treaties, (May 13, 2026)

Germany's upper house of parliament, the Bundesrat, has recently approved draft legislation that would amend the BEPS-MLI Implementation Act to expand the number of tax treaties concluded by Germany that are to be amended to newly include provisions to tackle tax base erosion and profit shifting.

Lawmakers agreed that the OECD should be notified, as Depositary of the BEPS MLI, that Germany will expand the scope of the instrument to a further 62 tax treaties.

The MLI enables countries to modify their existing tax treaties to include measures developed under the OECD/G20 BEPS project without having to individually renegotiate these treaties.

Jurisdictions may choose, when ratifying the BEPS MLI, which of their treaties they wish to amend through the MLI. These treaties are known as "covered agreements".

When Germany ratified the BEPS MLI, it selected just 14 of its agreements as covered agreements. In June 2025, it notified the OECD that it wished to expand coverage also to its treaties with the Czech Republic and Japan, and it also notified the OECD of the completion of domestic procedures enabling the entry into effect of provisions in the MLI on arbitration in respect of its treaties with Greece, France, Malta, Hungary, and Spain.

The new law would expand coverage of the BEPS MLI to a further 62 tax agreements. Earlier, the lower house of parliament approved the same legislation. Germany has yet to submit the required notification to the OECD.