Besitzen Sie diesen Inhalt bereits,
melden Sie sich an.
oder schalten Sie Ihr Produkt zur digitalen Nutzung frei.
German Implementation of the OECD’s Pillar Two
- Additional complexity without achieving the actual goal?
In the article, the author shortly describes Germany’s implementation of the EU Minimum Tax Directive. Furthermore, the legal status of provisions of the German Minimum Tax Act that are not directly based on the Directive are discussed. Subsequently, a German peculiarity the minimum tax group is examined. Before the contribution closes with an outlook, two selected provisions of the minimum tax law that are being discussed in Germany will be analysed in more detail.
I. Short overview over the German Minimum Tax Act
On December 28, 2023, the German implementation law for the Council Directive 2022/2523 of 14 December 2022 („MTD“) to ensure global minimum taxation for multinational corporate groups and large domestic groups in the Union came into force. The German Minimum Tax Act implements the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) as well as the Qualified Domestic Minimum Top-up Tax (QDMTT). The IIR and the QDMTT apply for financial years commencing on or after December 31, 2023, while the UTPR is applicable for financial years commencing on or after December 31, 2024. MNE groups based in Germany and large-scale domestic groups with a turnover of at ...