GloBE Country Guide: Germany

Summary

Status	Enacted Law
Law	On December 6, 2024, the Federal Ministry of Finance issued a Second Discussion Draft on amendments to the Minimum Tax Act. The updated Second Discussion Draft includes amendments for the June 2024 OECD Administrative Guidance. On October 17, 2024, Germany released the template for its Group Parent Notification Form. On December 27, 2023, Germany’s law to implement the Pillar 2 GloBE Rules/EU Minimum Tax Directive was published in the Federal Law Gazette 2023. On December 15, 2023, the Bundesrat (Germany’s Upper House of parliament) passed the Global Minimum Tax Act. It requires Presidential approval for enactment. On November 10, 2023, the Bundestag (Lower House) approved the German draft law to implement the EU Minimum Tax Directive. On August 16, 2023, the Federal Cabinet adopted the government draft for the implementation of the Pillar Two GloBE Rules. On 10 July 2023, the German Ministry of Finance published an updated version of the official draft legislation on the domestic implementation of the GloBE rules. On March 20, 2023, the German Federal Ministry of Finance published a consultation, including a draft law to implement the EU Global Minimum Tax Directive. On May 17, 2024, the Germany Finance Ministry issued a draft Global Minimum Tax Return to specialist publishers, software providers and associations for feedback. On August 20, 2024, the German Ministry of Finance issued a Discussion Draft of a Draft Law to implement most aspects of the Third 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 to the German GMT law.
Effective Date	January 1, 2024.
IIR	Yes (2024)
UTPR	Yes (2025)
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	CbCR Safe Harbour, Simplified Calculation Safe Harbour, Transitional UTPR Safe Harbour & the QDMTT Safe Harbour

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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