GloBE Country Guide: Germany


Status Enacted Law
LawOn 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.
Effective DateJanuary 1, 2024.
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursCbCR Safe Harbour, Simplified Calculation Safe Harbour, Transitional UTPR Safe Harbour & the QDMTT Safe Harbour

  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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