The new Minimum Tax Act (MinStG) will apply from January 1, 2024. Germany intends to implement key elements of the international agreements on Pillar 2 of the so-called G20/OECD two-pillar solution and ensure an effective global minimum tax rate of 15%.

We support you in all areas relating to minimum taxation, in particular

• The preparation of minimum tax returns for regular submission to the competent local tax office of the group parent company
• The preparation of minimum tax reports for submission to the BZSt
• The submission of the group head company report (“Gruppenträgermeldung”) to the BZSt, which is due by 28.02.25 at the latest. This also applies in the case of deviating financial years
• The examination of exceptions and simplifications
• Carrying out the simplified materiality test (less than €10 million revenue (Section 87 no. 2 MinStG) and less than €1 million profit or loss before tax), the substance test and the calculation of the simplified effective tax rate test
• In the context of the temporary safe harbor rules and so-called qualified country-by-country reports
• When recognizing deferred taxes. The transition year relevant for the recognition of deferred taxes is postponed accordingly by the period of the CbCR safe harbor regulation that is often used.