Germany’s Federal Ministry of Finance has issued a draft amendment to the Minimum Tax Implementation Ordinance (MinStDV) clarifying GloBE Information Return reporting rules, restructuring provisions and listing relevant tax jurisdictions under Annex I for corporate groups subject to the Minimum Tax Act (MinStG).
Germany’s Ministry of Finance (MoF) issued a draft amendment to the Minimum Tax Implementation Ordinance (Mindeststeuerdurchführungsverordnung – MinStDV) on 2 April 2026 to further define international reporting requirements under the Minimum Tax Act (Mindeststeuergesetz, MinStG).
The draft revises the previous Minimum Tax Report Ordinance and aims to clarify the scope, structure, and exchange of the GloBE Information Return, which corporate groups are required to submit under the MinStG in line with OECD standards. The Ministry of Finance is empowered under § 99 paragraphs 3 and 5 of the MinStG, with consent of the Federal Council (Bundesrat), to issue provisions governing reporting scope and information exchange.
The amended regulation is renamed as the Minimum Tax Implementation Ordinance (MinStDV) and is reorganised into four sections covering scope and definitions, reporting and information exchange, tax jurisdictions, and application provisions. It also introduces simplified reporting procedures for a transitional period in relation to the Minimum Tax Report.
An important aspect of the draft is Annex I, which lists tax jurisdictions that have implemented qualifying supplementary tax rules, including the effective dates of their regimes. It is intended to provide clarity for corporate groups and tax authorities on applicable jurisdictions under the GloBE framework.
The draft states that the provisions apply retroactively to fiscal years beginning after 30 December 2023 and will enter into force on the day following its publication. It also indicates that no additional administrative burden is expected, as compliance costs were already assessed under the original implementation of the EU global minimum tax directive.
Earlier, MoF released a draft bill to implement the Multilateral Competent Authority Agreement on the Exchange of GloBE Information Returns (GIR MCAA) on 20 March 2026.
