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ARTICLE · 04 APRIL 2023

First Draft Of German Implementation Of Global Minimum Taxation Published

Morrison Foerster
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The circulated draft of the German Implementation Act of Global Minimum Taxation Act ("Draft") is applicable to any entity group (multi-national, as well as domestic) with an annual turnover...

GermanyTax
Jens-Uwe Hinder
Jens-Uwe Hinder
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The German Federal Ministry of Finance circulated a first discussion draft of the implementation of the OECD-Guidelines for global minimum taxation, after the European Union therefore had published a Directive (Directive (EU) 2022/2523) in December 2022, leading the way for a harmonized implementation of the GloBE-Rules in all member states.

Introduction

The circulated draft of the German Implementation Act of Global Minimum Taxation Act ("Draft") is applicable to any entity group (multi-national, as well as domestic) with an annual turnover of at least EUR 750 million in at least two of the last four business years. As of December 31, 2023, such entities are subject to global minimum tax. The Draft contains three different mechanisms to ensure a global minimum taxation.

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