Deadline for the 2024 minimum tax is June 30, 2026
Minimum tax takes effect for the first time in 2024
The Minimum Tax Act (MinStG), which transposed the OECD rules on Global minimum taxation (so-called Pillar Two) into German law, is to be applied for the first time in 2024 — assuming a fiscal year that coincides with the calendar year. This applies to multinational corporate groups with consolidated annual revenue exceeding 750 million euros that have at least one constituent entity (company or permanent establishment) in Germany. The deadline for the initial filing for the year 2024 is June 30, 2026.
GIR has to be submitted to the German Federal Central Tax Office (BZSt)
At that time, companies subject to the MinStG must electronically submit their GloBE Information Return (GIR) to the German Federal Central Tax Office (BZSt) in accordance with the officially prescribed data format and via the officially designated interface. This report contains all — in some cases highly complex — calculations for determining the top-up taxes according to Income Inclusion Rule (IIR), Undertaxes Profits Rule (UTPR / starting in 2025), and Qualified Domestic Minimum Top-Up Tax (QDMTT). If there are multiple domestic constituent entities, one of these entities may submit the report on behalf of the other entities. If the ultimate parent company of the group is resident in Germany, it generally prepares and submits the GIR.
In inbound cases, the German constituent entities are exempt from submitting the GIR if the foreign Ultimate Parent Entity or another entity commissioned by it has filed the report in its respective country of residence and there is an international agreement between Germany and that jurisdicition regarding the automatic exchange of GIR. This requirement is met for EU member states through the EU Directive on Administrative Cooperation (DAC 9).
No automatic exchange yet for third-country cases
For third-country cases, the Multilateral Agreement between the Competent Authorities on the exchange of GloBE information is intended to ensure the exchange and prevent multiple submissions within the same group. Germany signed this agreement on September 19, 2025; implementation still requires a national law. The Federal Ministry of Finance (BMF) submitted a draft bill on this matter on March 20. However, it is expected that the legislative process will not be completed until after June 30, which is after the statutory deadline for submitting the GIR. Therefore, unless the German tax authorities introduce procedural simplifications at short notice, the affected multinational groups would be well advised to submit their GIR for 2024 in Germany as well. This also applies to groups with parent companies, for example, in Japan, South Korea, Canada, Singapore, Switzerland, or the United Kingdom, which have also signed the agreement. Countries that have not yet implemented the global minimum tax (e.g., the U.S. or China) will consequently not participate in the exchange.
Local Tax offices receive minimum tax returns
The same deadline (June 30, 2026, for the year 2024) applies to the filing of the minimum tax return. This must be submitted as a tax return to the locally competent tax office. The respective group head is responsible for filing the return for all domestic constituent entities. If the ultimate parent entity is resident in Germany, it is also the group head. A minimum tax return must also be filed in cases where the minimum tax is zero - for example, because the corporate group is making use of the transitional provisions and meets at least one of the so-called CbCR safe harbors for all jurisdictions.
Status of implementation: country overview
To provide a clearer overview in which countries and at what times the individual components of the global minimum tax were introduced and officially recognized by the OECD, the Federal Ministry of Finance (BMF) submitted a draft amendment to the relevant statutory regulation on April 8. This includes, as an annex, a country-specific overview that affected corporate groups and tax authorities can use as a guide, for example, to verify the requirements of certain safe harbor provisions.
Global compliance as a challenge
The implementation of the Global minimum tax poses major challenges for all affected multinational groups. While the focus in recent months has primarily been on the internal collection of data and the performance of complex calculations, all compliance requirements must now be met and coordinated globally within the group. If you need assistance with this, please feel free to contact one of our experts.