The rule applies to multinational enterprise groups that report effective tax rates across jurisdictions under Germany’s Minimum Tax Act, which enacts the Pillar 2 global minimum tax framework.
Germany’s Federal Council (Bundesrat) approved a regulation implementing the country’s minimum taxation law on 19 December 2025.
The rule applies to multinational enterprise groups that report effective tax rates across jurisdictions under Germany’s Minimum Tax Act, which enacts the Pillar 2 global minimum tax framework.
The regulation introduces new provisions detailing the specific design and the exchange of information relating to the minimum tax report. The minimum tax report must be submitted by certain corporate groups that are subject to reporting obligations under the Minimum Tax Act (Section 75 of the Minimum Tax Act).
In Germany, the minimum tax was introduced under the Minimum Tax Act on the basis of an EU Directive from 2022. It serves the global taxation of large, internationally operating companies and corporate groups with annual revenues of at least EUR 750 million.
Among other things, the regulation contains rules on the content and preparation, the structure, and the transmission of the minimum tax report.
The regulation will take effect upon its publication in the Official Gazette.
Earlier, the German Ministry of Finance (MOF) published a draft ordinance setting out the rules for filing and exchanging the GloBE Information Return (GIR) on 29 September 2025.
