Germany approves the GloBE information-return exchange agreement

The law approves Germany’s participation

The statute gives domestic approval to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information Returns dated 15 January 2025. The agreement was signed for Germany in Paris on 19 September 2025. It establishes the competent-authority framework for exchanging information from the GloBE information return used to administer the global minimum tax. Article 1 approves both the agreement and the official German translation.^[1]

Approval and activation are different steps

The approval statute took effect on 6 October 2026, the day after its promulgation. That does not by itself make every exchange relationship operational. Article 2(2) requires the date on which the agreement enters into force for Germany under section 8(2) to be announced separately in the Federal Law Gazette. Section 8 also makes an exchange relationship jurisdiction-specific: the relevant competent authorities must submit matching notifications that identify one another before an active relationship exists. The approval law should therefore not be read as evidence that any particular bilateral exchange channel is active.^[1]

German filing relief depends on effective exchange

Section 75(1) of the Minimum Tax Act (Mindeststeuergesetz) generally requires an in-scope German constituent entity to submit the minimum-tax report to the Federal Central Tax Office, although one German entity may file for the other German entities. Under section 75(2), filing by the ultimate parent or a designated filing entity outside Germany removes that local obligation only where the filing jurisdiction is an EU Member State or has an effective international agreement providing automatic exchange with Germany for the relevant fiscal year.^[2]

Groups should test the relationship for each year

Groups relying on a non-EU central filing should verify the Germany-specific exchange relationship for the reporting year instead of relying only on signature or parliamentary approval of the agreement. Section 75(3) sets a 15-month filing deadline after year end, extended to 18 months for the first report; section 75(4) prevents the first deadline from falling before 30 June 2026. The practical question is therefore whether a qualifying exchange arrangement is effective when the German filing obligation is tested.^[1][2]