On September 29, 2025, the Federal Ministry of Finance opened a consultation on a Draft Regulation for the implementation of the Minimum Tax Act. This provides for compliance rules for the exchange of the GIR and simplified reporting.

On August 6, 2025, Germany issued the draft bill to amend the Minimum Tax Act. This follows the two previous discussion drafts and now includes the January 2025 OECD Administrative Guidance and DAC9 amendments.

On April 3, 2025, the Federal Ministry of Finance issued a letter on the application of Country-by-Country (CbC) reporting for transparent partnerships, including the impact on the Transitional CbCR Safe Harbour for Pillar 2 purposes.

In this article we look at the implementation of the Pillar 2 Global Minimum Tax in Germany, including the implementation of the OECD Administrative Guidance.

On December 6, 2024 Germany’s Ministry of Finance issued a Second Discussion Draft to implement aspects of the Fourth Set of OECD Administrative Guidance.

On November 22, 2024, the Annual Tax Act was passed by the Upper House of Parliament. This includes two technical changes relating to the Global Minimum Tax

On October 17, 2024, Germany released its Group Parent notification form for German minimum tax groups. Section 3 of the German GMT law provides that the Group Parent of the German minimum tax group is required to register with the Federal Tax Authority within 2 months of the end of the relevant fiscal period (ie February 28, 2025 for the 2024 fiscal year).