Global Minimum Tax: New Obligations for International Companies in Germany

Starting in 2026, new rules related to the global minimum tax apply in Germany. The regulations are part of the international tax reform developed by the OECD (Pillar 2) and implemented in Germany through the Minimum Tax Act (Mindeststeuergesetz).

For multinational corporate groups, these rules introduce new reporting obligations and additional requirements in the area of tax compliance.

What is the Global Minimum Tax

The global minimum tax establishes a minimum effective corporate tax rate of 15% on profits of large multinational enterprises worldwide.

The main objective of the reform is to reduce profit shifting to low-tax jurisdictions and to create a more balanced international tax framework.

The rules apply to multinational corporate groups with annual consolidated revenues exceeding €750 million.

If the effective tax rate in a particular jurisdiction falls below the minimum threshold, an additional tax may become payable.

New Reporting Obligations in Germany

Following the implementation of the EU directive, affected corporate groups must submit new tax reports to the German tax authorities.

A key deadline is 30 June 2026.

By this date, companies may need to submit:

• a notification regarding the application of the global minimum tax
• a minimum tax report for the corporate group
• additional information to the Federal Central Tax Office (Bundeszentralamt für Steuern – BZSt)

These reports generally include information on group profits, effective tax rates and the structure of the multinational group across jurisdictions.

What This Means for Businesses

For many international companies, the global minimum tax creates new tax and compliance challenges.

Businesses should be prepared to:

• consolidate financial information from multiple jurisdictions
• analyze the effective tax rate in each country
• adjust internal tax reporting and compliance procedures

Early preparation can help reduce risks and ensure that reporting obligations are fulfilled in a timely and accurate manner.

Conclusion

The introduction of the global minimum tax represents one of the most significant developments in international tax law in recent years.

Companies that fall within the scope of these rules should review their tax structures and reporting processes to ensure compliance with the new requirements under German law.