Global Daily Tax News, Germany To Add BEPS Provisions To More Than 60 Treaties, (Oct 17, 2025)

The German Government has tabled draft legislation to substantially expand the coverage of the BEPS multilateral instrument to more of the nation's bilateral double tax agreements.

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 this year, 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.