December 4, 2025

Pillar 2 – Deutschland: German Implementation of the OECD’s Pillar Two — - Additional complexity without achieving the actual goal?

Key Points

Implementation presents challenges in adhering to the EU Minimum Tax Directive, and may not achieve intended outcomes.
Key provisions of the German Minimum Tax Act reveal complexities in execution and interpretation.
Analysis illustrates the situation surrounding the minimum tax group under German law, highlighting its peculiarity and implications.
Significant gaps indicate that while reforms are in place, full alignment with the OECD's objectives remains elusive.

Abstract

Abstract 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.

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Cite This Study

Magdalena Schwarz (Wed,) studied this question.

synapsesocial.com/papers/6930e8d7ea1aef094cca3a1d https://doi.org/https://doi.org/10.9785/isr-2025-141008

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