Germany approves OECD pact for automatic GloBE return exchange

Germany has given domestic legal force to the multilateral competent authority agreement on exchanging GloBE information returnsBund, the instrument that lets an ultimate parent entity file the global minimum tax return once centrally instead of in every jurisdiction. The approval act was published as Bundesgesetzblatt Teil II Nr. 220, ausgegeben zu Bonn on 5 October 2026Bund, for the Mehrseitige Vereinbarung vom 15. Januar 2025 zwischen den zuständigen Behörden über den Austausch von GloBE-InformationenBund, signed by Germany in Paris on 19 September 2025 and printed with an official German translation. Article 1 approves the agreement; Article 2 puts the act into force on the day after promulgation, so 6 October 2026Bund. The day the agreement itself enters into force for Germany under its Section 8(2) will be announced separately in the BundesgesetzblattBund; the constitutional rights of the Bundesrat are recorded as preserved.

The agreement organises automatic exchange of GloBE information returns between competent authorities under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters. Each competent authority exchanges, with every authority with which it has an active exchange relationship, the return information received from an ultimate parent entity or designated filing entity located in its jurisdiction that is relevant to the receiving jurisdiction under the Dissemination Approach. The GloBE return has a general section on the group as a whole and jurisdictional sections reflecting the detailed application of the GloBE rules and any Qualified Domestic Minimum Top-up Tax (QDMTT) in each jurisdiction where the group operates; the dissemination approach determines which sections each implementing jurisdiction and each QDMTT-only jurisdiction receives. This agreement is itself a Qualifying Competent Authority Agreement, so a constituent entity is discharged from local filing where the return is filed on time by the ultimate parent entity or designated filing entity in a jurisdiction holding such an agreement with the local jurisdiction.

Exchange runs on fixed clocks. Return information is exchanged no later than three months after the filing deadline in the sending jurisdiction for the reporting fiscal year concerned, six months for the first reporting fiscal year a competent authority indicates in its notification, and within three months of receipt for returns received after the sending jurisdiction's filing deadline. Transmission uses a common XML schema through the OECD Common Transmission System with the applicable encryption and file-preparation standards. Competent authorities cooperate on corrections: an authority that believes return information needs correction notifies the other authority, which obtains corrected information from the parent or filing entity and re-exchanges it; where expected information never arrives, the receiving side is told the reason within one month with the expected exchange date.

An exchange relationship becomes active once both sides have notified the Co-ordinating Body Secretariat naming each other's jurisdiction; the Secretariat publishes the list of active relationships on the OECD website. Relationships can be deactivated in writing, effective for reporting fiscal years starting after the notice, or immediately for a confidentiality breach; participation can be terminated on 30 months' notice, with previously received information remaining confidential.

For German groups the domestic relief sits in the Mindeststeuergesetz (MinStG): the local filing duty under § 75 falls away where the Mindeststeuer-Bericht is filed by the ultimate parent entity in an EU Member State or a state with an effective agreement providing automatic exchange of such reports with Germany.

Legal basis: Gesetz zu der Mehrseitigen Vereinbarung vom 15. Januar 2025 zwischen den zuständigen Behörden über den Austausch von GloBE-Informationen (BGBl 2026 Teil II Nr. 220), Articles 1-2; Mindeststeuergesetz §§ 75, 75a.