Germany Pillar Two Filing Guide

This guide is focused on the German Pillar Two filings administered by the Federal Central Tax Office (Bundeszentralamt für Steuern, BZSt): the group head notification under Section 3 of the Minimum Tax Act (Mindeststeuergesetz, MinStG) and the GloBE Information Return (GIR). It also covers the practical registration steps that sit behind the electronic transmission process. Members can also download our PDF Germany Pillar Two Filing Checklist. 

Germany’s procedure is split. The BZSt receives the group head notification and the GIR. The minimum tax return itself is filed with the competent state tax office. That means a German compliance calendar now usually has at least three workstreams: group head notification, GIR preparation/transmission, and the domestic minimum tax return.

Overview

Germany brought the Pillar Two filing framework online for fiscal years beginning in 2024. In-scope Groups with Constituent Entities in Germany are required, from the 2024 fiscal year, to submit a group head notification, a GIR and a minimum tax return. The group head notification was first filed in 2025, while the GIR and the minimum tax return are first filed in 2026.

The German process is not a single return in a single portal. The group head notification is a form-driven filing. The GIR is a structured XML transmission. The minimum tax return sits with the competent state tax office. In practice, taxpayers need to keep those tracks separate internally, even if the same tax team coordinates them.

Timing rules 

For the group head notification, Germany uses a short and strict deadline. The group head or its representative must submit the notification no later than two months after the end of the tax period for which liability under the Minimum Tax Act exists. The tax period is the calendar year under Section 94 sentence 2 MinStG. As a result, where the group’s fiscal year differs from the calendar year, the notification is still due by 28 February of the year following the end of that fiscal year, and the fiscal year of the Ultimate Parent Entity is decisive.

The GIR has the longer OECD timing window, with the first GIR due no later than 18 months after the end of the fiscal year for which a GIR has to be prepared for the first time. In later years, the deadline moves to 15 months after fiscal year end. For many calendar-year groups, that means the first German GIR cycle lands in 2026.

Registration and access

In Germany there is both a portal-access layer and a Pillar Two data-transmission layer.

At the portal level, the BZSt online portal states that users can log in with an ELSTER certificate, a BZSt certificate or the federal user account (Nutzerkonto Bund). Some forms require deeper verification, so a simple BundID username/password login will not always be enough in practice.

For Pillar Two transmission itself, the BZSt’s Pillar Two FAQ and electronic transmission page describe an additional onboarding step. First, the filer completes the Pillar Two registration form. In addition, the data transmitter must send a commercial register extract or comparable document to the BZSt e-mail address stated in the Pillar Two materials, and the BZSt asks the filer to mention when the registration form was sent. After the registration application has been checked, the BZSt sends a BZSt number by letter and a BZSt secret by e-mail. Those credentials are used to download a BZSt certificate.

How the group head notification works

The group head notification is Germany’s mechanism for establishing who bears the Pillar Two filing and tax compliance role for the minimum tax group. The group head is determined via a top-down logic.

If the Ultimate Parent Entity is located in Germany, it is generally the group head. If the Ultimate Parent Entity is not located in Germany, the parent entity located in Germany is the group head where it is the joint parent of all German Constituent Entities. If neither of those rules identifies the group head, the Ultimate Parent Entity must designate one liable German Constituent Entity as group head until the decision is revoked. If no such designation is made, the tax authorities determine the group head.

The notification is not a one-time filing forever. If the group head changes, the previous group head has to file a revocation of the old notification and the new group head has to submit a new notification. If the group head stays the same but its data changes, for example its address, Germany expects a corrected group head notification.

The BZSt procedure materials also show the core data content of the group head notification: name and address details of the group head and the Ultimate Parent Entity, the tax ID number of the group head and the Ultimate Parent Entity, information on the legal obligation of group member status, and contact details for a contact person. 

How the GIR is filed in Germany

The GIR is not filed in Germany as a web form. The GIR is transmitted to the Federal Central Tax Office in the prescribed XML format via the mass data interface DIP (Digitaler Posteingang, or Digital Inbox). As such mass data uploads still run through the established mass-data route rather than a simple in-browser upload screen.

In practical terms, a German GIR filing usually follows this sequence:

1. determine whether the German filing role is local filing or another GIR role under the OECD logic;
2. prepare the GIR XML in the BZSt-prescribed structure;
3. validate both the Germany-specific transmission wrapper and the GIR content;
4. ensure the registered data transmitter and certificate are active;
5. transmit the XML through the mass-data channel; and
6. retain the submission identifiers and confirmation trail for later corrections or authority queries.

The GIR filed in Germany will be transmitted onward by the BZSt to the competent authorities of the relevant jurisdictions if Germany is entitled to receive and exchange the GIR under the applicable exchange framework. 

Germany-specific XML issues