Skip to Content

The Convention to Implement Measures to Prevent BEPS will Have Effect with respect to the Tax Treaty with Germany

Japanese

June 13, 2025

Ministry of Finance

The Convention to Implement Measures to Prevent BEPS will Have Effect with respect to the Tax Treaty with Germany

[Provisional translation]

1. According to the publication as of June 1, 2025 by the Secretary-General of the Organisation for Economic Co-operation and Development (OECD) acting as the Depositary of the "Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting" (Convention to Implement Measures to Prevent BEPS), Germany submitted the notification that it had completed its internal procedures for the entry into effect of the provisions of this Convention with respect to the tax treaty between Japan and Germany.

2. The provisions of this Convention, accordingly, shall have effect in each Contracting Jurisdiction with respect to the tax treaty between Japan and Germany:
(a)　with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after January 1, 2026; and
(b)　with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after January 1, 2026.

3. For the details of the application of this Convention to the tax treaty between Japan and Germany, see the webpage below.

◆The text of the Convention to Implement Measures to Prevent BEPS
“Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting”（Japanese(PDF:997KB)・English(PDF:269KB) ）

◆List of Reservations and Notifications of Signatories and Parties to the Convention to Implement Measures to Prevent BEPS [link to the website of the OECD]

◆Convention to Implement Measures to Prevent BEPS (MLI)
└List of Reservations and Notifications of Japan（Japanese(PDF:491KB)・English(PDF:414KB)）
└Application of the MLI to Japan's Tax Treaties
　　[Germany]
　　　└Summary
　　　└Synthesised Text (Japanese(PDF:248KB)・English(PDF:118KB))

◆Tax Treaties Covered by the Convention to Implement Measures to Prevent BEPS will be Increased [ Germany and Pakistan ] (January 8, 2021)(Link to National Diet Library)
HOME