#BGBl. 2025 I Nr. 353Law on the Adaptation of the Minimum Tax Act and the Implementation of Further Measures
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This German federal law, published in the Bundesgesetzblatt on 23 December 2025, amends the Minimum Tax Act (Mindeststeuergesetz) which implements the OECD/G20 global minimum tax (Pillar Two) of 15% for large multinational enterprises. The legislation introduces technical adjustments to align with updated international standards and EU directives while also enacting several unrelated tax administration and fiscal measures. It was drafted under the lead of the Federal Ministry of Finance and covers areas including general tax law, property and transaction taxes, and financial administration.
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Key Changes
- Technical amendments to the German Minimum Tax Act to align with updated OECD Model Rules and EU Directive requirements
- Adjustments to safe harbour provisions and calculation methodologies for the 15% effective tax rate
- Modifications to filing and reporting obligations for multinational groups with German presence
+ 2 more changes with Pro
Obligations
What this law requires
Large multinational enterprises must apply a global minimum tax rate of 15% on their income as implemented through amendments to the Mindeststeuergesetz (Minimum Tax Act)
Taxpayers and tax administrators must comply with technical adjustments made to the Minimum Tax Act to align with updated international OECD/G20 standards and EU directives