#BGBl. 2025 I Nr. 373Regulation on the Implementation of the Minimum Tax Act concerning the Scope, Design and Exchange of Information on Minimum Tax Reports
AI-generated summary for informational purposes only. Not legal advice. See the original source for the authoritative text.
This German regulation (Mindeststeuer-Bericht-Verordnung — MinStBV), published in the Federal Law Gazette on 29 December 2025, implements detailed rules under the Minimum Tax Act. It specifies the exact scope of minimum tax reports that multinational enterprise groups must prepare and file, the required format and content of these reports, and the mechanisms for automatic exchange of information between tax authorities. The ordinance establishes technical and procedural requirements to ensure consistent application of the 15% global minimum tax (Pillar Two) across Germany and with partner jurisdictions. It defines which entities are obligated to submit reports, the specific data points that must be included, and the secure channels through which tax administrations will share the reported information internationally.
AI-generated summary. May contain errors. Refer to official sources for legal decisions.
Key Changes
- Establishes detailed content requirements and standardized format for Minimum Tax Reports under the German Minimum Tax Act
- Defines scope of entities and groups subject to reporting obligations for the 15% global minimum tax
- Regulates procedures and technical specifications for automatic exchange of minimum tax information with foreign tax authorities
+ 3 more changes with Pro
Obligations
What this law requires
Multinational enterprise groups must prepare and file minimum tax reports in accordance with the scope and format specifications defined in this regulation
Obligated entities must include all specific data points required by this regulation in their minimum tax reports
Minimum tax reports must be submitted in the exact format and design specifications established by this regulation
Tax administrations must automatically exchange minimum tax report information with partner jurisdictions through secure channels as specified in this regulation
Entities must use the secure transmission channels designated by tax authorities for submitting minimum tax reports