Germany releases draft amendments to Pillar Two rules

The legislation proposes to implement new OECD Administrative Guidance and simplify individual anti-profit shifting regulations.

The German Ministry of Finance, on August 8, 2025, published draft amendments to the Minimum Tax Act which would implement new OECD Administrative Guidance items from 15 December 2023, 24 May 2024, and 13 January 2025. The draft legislation would also simplify individual anti-profit shifting regulations to avoid bureaucracy. The following measures should be emphasised. Minimum Tax Act Flow-through entities The definitions of flow-through, tax-transparent and reverse hybrid entities will...

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Published Date: 28 August 2025