Close
An overview by Flick Gocke Schaumburg, Taxand Germany
Germany introduced its Minimum Tax Act on 1 January 2024 to implement Pillar 2, requiring multinational enterprises (MNEs) to pay a minimum 15% effective tax rate in line with OECD Model Rules and EU Directive requirements.
The Act has encountered delays, technical issues, and political debate – including a motion to suspend Pillar 2 that was ultimately rejected – but forthcoming amendments are expected to bring it in line with the latest OECD/G20 guidance. Compliance remains complex, particularly regarding group accounting, hybrid entities, and deferred taxes, and many MNEs are relying on Safe-Harbour relief while preparing for the first Pillar 2 and GloBE filings due by 30 June 2026.
Dr. Nils Linnemann from our German member firm Flick Gocke Schaumburg has published a detailed overview of Germany’s implementation, which can be read here, emphasising that ongoing monitoring of OECD and G20 developments is crucial, as any future simplifications will still require careful planning to manage tax and compliance risks.
For similar content to our Global Guide, subscribe to our mailing list and keep up to date.