Germany Approves and Updates its GloBE Law

  1. Overview
  2. Section 27 – Qualified Refundable Tax Credits
  3. Section 28 – Marketable Transferable Tax Credits
  4. Section 29 – Treatment of Investments in Certain Tax Transparent Entities
  5. Section 54 – QDMTT Challenged
  6. Section 59/60(1) – Interjurisdictional Employees/Assets for the Substance-based Income Exclusion
  7. Section 60 – Substance-based Income Exclusion: Other Assets
  8. Section 79 – Permanent Simplified Safe Harbours
  9. Section 80 – Non-Material Constituent Entities
  10. Section 81 – QDMTT Safe Harbour
  11. Section 89 – Transitional UTPR Safe Harbour
  12. Section 97 – Currency


On November 10, 2023, the Bundestag (Lower House) approved the German draft law to implement the EU Minimum Tax Directive.

It will need the approval of the Bundesrat (Upper House) and will then need to be signed by the President and published in the Official Gazette before the law is enacted and promulgated. 

There were a number of significant amendments to the original government draft law (approved by the Federal Cabinet on August 16, 2023) during the legislative process.

Most notably, the latest updated draft law implements numerous aspects of the Second Set of OECD Administrative Guidance (issued in July 2023). The original draft law already included most aspects of the First Set of OECD Administrative Guidance (see our OECD Administrative Guidance: Domestic Implementation Matrix).

Section 27  – New Provision for Qualified Refundable Tax Credits (QRTCs)

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