Germany Pillar Two Filing Guide
March 27, 2026
A practical guide to Germany’s Registration, group head notification and GloBE Information Return (GIR) filing through the BZSt framework
A practical guide to Germany’s Registration, group head notification and GloBE Information Return (GIR) filing through the BZSt framework
On December 23, 2025, Germany enacted a law to amend the Minimum Tax Act. This follows the two previous discussion drafts and now includes the January 2025 OECD Administrative Guidance and DAC9 amendments.
On September 29, 2025, the Federal Ministry of Finance opened a consultation on a Draft Regulation for the implementation of the Minimum Tax Act. This provides for compliance rules for the exchange of the GIR and simplified reporting.
On April 3, 2025, the Federal Ministry of Finance issued a letter on the application of Country-by-Country (CbC) reporting for transparent partnerships, including the impact on the Transitional CbCR Safe Harbour for Pillar 2 purposes.
In this article we look at the implementation of the Pillar 2 Global Minimum Tax in Germany, including the implementation of the OECD Administrative Guidance.
On December 6, 2024 Germany’s Ministry of Finance issued a Second Discussion Draft to implement aspects of the Fourth Set of OECD Administrative Guidance.
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