New regulation sets out detailed procedures for filing and exchanging GloBE information returns for multinational groups, effective from 30 December 2025.
Germany has introduced detailed rules for filing and exchanging Global Anti-Base Erosion (GloBE) information returns for multinational enterprises under the Pillar 2 global minimum tax, as set out in the Mindeststeuer-Bericht-Verordnung (MinStBV) published in the Official Gazette on 29 December 2025.
The regulation implements the Minimum Tax Act (Mindeststeuergesetz – MinStG), defining key terms, the structure of the GloBE Information Return (GIR), and the framework for automatic exchange with other jurisdictions. Transitional provisions allow simplified reporting for fiscal years ending before 1 July 2030 under certain conditions.
The Federal Central Tax Office (Bundeszentralamt für Steuern) is the authority responsible for receiving and forwarding the reports. The regulation identifies three types of tax jurisdictions: implementing tax jurisdictions (IIR/UTPR), QDMTT-only jurisdictions, and SES jurisdictions.
The GIR is divided into three main sections:
- General Section – an overview of the corporate group and GloBE information.
- Country-Specific Sections – details on GloBE application and national supplementary taxes for each jurisdiction.
- SES Section – allocation of the secondary supplementary tax (UTPR) for specific jurisdictions.
Automatic exchange rules specify that the jurisdiction of the Ultimate Parent Entity receives all country-specific data. Other jurisdictions receive only the sections relevant to their tax rights, while QDMTT-only jurisdictions receive the general section for resident entities or joint ventures.
For fiscal years starting on or before 31 December 2028 and ending before 1 July 2030, groups may use simplified reporting. This allows aggregated reporting by jurisdiction and net adjustments where no top-up tax is due. Reports must follow GloBE Model Rules, and any differences from local legislation must be disclosed.
The regulation took effect on 30 December 2025.
