German Ministry of Finance issues a draft ordinance revising the Minimum Tax Report Regulation (MinStBV), renaming it the Minimum Tax Implementation Regulation and updating reporting, jurisdictional listing, and information exchange rules under the Minimum Tax Act (MinStG).
The German Federal Ministry of Finance has issued a draft ordinance on 8 April 2026 proposing amendments to the minimum tax report ordinance (MinStBV), including a structural and legal update to reporting rules under the Minimum Tax Act (MinStG).
Under Section 75 of the Minimum Tax Act (MinStG), corporate groups are required to submit a minimum tax report. The draft seeks to refine the scope, design, and international exchange of information relating to these reports, which have also been developed further at international level.
A key element of the proposal is the formal renaming of the ordinance to the Minimum Tax Implementation Regulation (MinStDV). It also introduces a reorganised framework divided into four sections covering scope and definitions, reporting requirements and information exchange, designation of tax jurisdictions, and application rules.
The draft additionally provides for Annex I, which lists tax jurisdictions that have implemented qualified top-up tax rules, along with their respective effective dates. This is intended to give corporate groups and tax authorities legal certainty in determining minimum tax obligations across jurisdictions.
The proposal also establishes a framework for automatic exchange of information between tax authorities and aligns domestic rules with international standards, including EU requirements. It applies to fiscal years beginning after 30 December 2023 and is intended to ensure consistent legal application without introducing additional compliance costs, as these are already covered under existing legislation.
Earlier, Germany 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.
