Germany in focus: making sense of MiKaDiv

September 09, 2026
  • Investor Services
A new German withholding tax reporting framework could provide greater transparency and help eliminate fraud but will place new responsibilities on investors and their service providers.

The introduction of MiKaDiv1, part of the Germany’s overarching implementation of its Withholding Tax Modernization Act, is designed to simplify and digitize domestic dividend tax reporting.

The Act is meant to address inefficiencies and vulnerabilities Germany experiences in its paper-based tax system model.

Historically, the administrative process relied on tax certificates to reclaim German withholding tax, however this process proved vulnerable to errors and exploitation.

Digital switchover

In 2027, a mandatory digital reporting framework for investment income, including dividends and interest payments, will replace paper-based tax certificates or vouchers with automated digital reporting.

The goal of MiKaDiv is to enable the German Tax Authorities (“GTA”) to track custody chains and transaction timing more closely, enabling mode control over tax relief granted to recipients on investment income.

Under the model, financial institutions - including German paying agents, custodians, and domestic listed companies - must report dividend-related capital gains digitally to the GTA using standardized XML data schema.

MiKaDiv will replace paper vouchers with the issuance of unique reference numbers (UUID), received by investors, which are required in part to substantiate claims for relief.

Under the new procedure, the German sub-custodians/securities depositories will share transaction payment details with the GTA who will, in turn, issue the UUID.

Investor impacts in focus

The key impact to investors will be an onus to provide data, documentation, and certifications/attestations of their eligibility for relief to their relevant custodian.

Investors will need to:

  • Supply information and documentation as they do today to achieve relief / tax reclaims
  • Provide additional supporting information about their transactions in German securities

Included in new reporting requirements is the need to declare whether the transaction is related to a ‘Financial Arrangement2’ that could preclude their eligibility for treaty benefits or reclaims.

Investors claiming tax rates below 15% are required to meet a holding period requirement, set at 45 days pre and post the record date.

Why MiKaDiv matters to financial intermediaries

As part of the model, financial intermediaries including custodians, sub-custodians and paying agents will be required to transmit information to the GTA via the incoming digital reporting system.

The reporting requirement carries considerable weight, and financial intermediaries which are not MiKaDiv ready by the deadline will not be able to support providing tax relief to customers/investors.

FASTER progress

While MiKaDiv is primarily designed to form part of Germany’s Withholding Tax Modernization Act, aspects of it are being adopted under the broader European Union FASTER Directive. MiKaDiv’s introduction was postponed until 2027 to facilitate joint implementation with FASTER in Germany.

FASTER is intended to harmonize and bring enhanced control to countries’ withholding tax regimes across EU member states.

Among its various facets, the Directive will introduce a common EU Member State electronic Tax Residence Certificate (eTRC). It will also oblige certain intermediaries to become Certified Financial Intermediaries (CFIs).

The European Commission is currently working on various implementing Acts for FASTER, with EU member states scheduled to transpose the Directive into national law by December 2028.

If you have any questions or would like further information, please reach out to David Weisner or Alina Kirzner.

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1 MiKaDiv, stands for Mitteilungsverfahren Kapitalerträge Dividenden or Dividend Income Reporting Procedure in English.

“Financial Arrangements” refer to arrangements between parties that affect the applicability of tax relief to the recipient of the investment income.

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