Bundesrat has approved amendments to the Minimum Tax Reporting Ordinance, renaming it the Minimum Tax Implementation Ordinance (MinStDV) and expanding its scope to identify jurisdictions with qualified minimum tax rules while maintaining the framework for the automatic exchange of minimum tax reporting information with EU member states.
Germany’s Federal Council (Bundesrat) approved the amendment of the regulation on the application of the minimum taxation law (Mindeststeuer-Bericht-Verordnung – MinStBV) on 10 July 2026.
The measure expands the framework under the Minimum Tax Act (MinStG) by identifying jurisdictions that have implemented qualified minimum tax rules, while retaining provisions governing the automatic exchange of minimum tax reporting information with other EU member states.
Renaming and expanded scope
The ordinance renames the Minimum Tax Reporting Ordinance (Mindeststeuer-Bericht-Verordnung – MinStBV) as the Minimum Tax implementation Ordinance.
A key change is the formal designation of tax jurisdictions that have implemented qualified domestic top-up tax rules, primary tax rules, or secondary tax rules as defined under the Minimum Tax Act (MinStG). The amendment also introduces editorial revisions and restructures the regulation to reflect its expanded scope.
Four-part structure
The MinStDV is organised into four sections:
- Section 1: Scope and definitions.
- Section 2: Scope, design and information exchange of minimum tax reports.
- Section 3: Designation of specific tax jurisdictions through a detailed Annex (Anlage).
- Section 4: Application rules.
The ordinance continues to regulate the automatic exchange of information relating to minimum tax reporting obligations with other EU member states.
Compliance impact
The Federal Ministry of Finance said the ordinance does not impose additional compliance costs on citizens, businesses, including small and medium-sized enterprises, or the public administration.
According to the ministry, all fulfilment costs had already been taken into account under the legislation implementing the EU Global Minimum Taxation Directive (Directive (EU) 2022/2523). The measure also supports the German Sustainable Development Strategy by helping to secure state tax revenue.
Effective date
The provisions of the Minimum Tax Implementation Ordinance (MinStDV) apply to fiscal years beginning after 30 December 2023. It will enter into force after its publication in the Official Gazette.
