On August 7, 2026, Germany published a regulation that gives domestic legal effect to a jurisdiction-by-jurisdiction list of qualifying Pillar Two jurisdictions.
Germany’s Federal Ministry of Finance published the Draft Annual Tax Act, 2026 on May 19, 2026. Key changes include implementation of aspects of the OECD January 2026 Side-by-Side Package.
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.
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