German Annual Tax Act Includes GMT Amendments

On November 22, 2024, the Annual Tax Act was passed by the Upper House of Parliament. 

The initial draft of the Annual Tax Act 2024, included an amendment to the Substance-based Income Exclusion to align with OECD Administrative Guidance. (see the draft Annual Tax Act 2024 including the justifications for the individual amendments on the website of the Federal Ministry of Finance.)

The recommendations of the Finance Committee – which were followed by the Bundestag (Lower House of Parliament) – can be found here. This includes a further amendment relating to the German group parent for the purposes of the German Minimum Tax Group provisions. The Annual Tax Act was passed by the lower house of Parliament on October 18, 2024.