Partner
Certified Tax Advisor, Graduate in Business Administration
Pillar 2 | Overview
Pillar 2 sets new standards in corporate taxation. The implementation rules are complex. Staying up to date is not easy. We keep you informed about all developments regarding global minimum taxation and provide clarity and guidance.
Thomas Stengel
Associate Partner
Certified Tax Advisor, Certified Tax Advisor
Diana Fischer
Partner
Certified Tax Advisor, Graduate financial management
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Pillar 2 is part of the OECD BEPS initiative. The goal is to introduce a global effective minimum taxation of 15 percent for corporate groups with consolidated revenues exceeding 750 million Euros. The taxation system is developed by the OECD, and its implementation is carried out by individual member states.
International Implementation
- OECD GloBE Model Rules: published in December 2021.
- EU Directive 2022/2523: adopted in December 2022. It obliges EU member states to introduce national minimum taxation regulations.
Implementation in Germany
- Minimum Tax Act (MinStG): in force since December 28, 2023.
- Minimum Tax Adjustment Act (MinStAnpG): published in the Federal Law Gazette on December 23, 2025.
- Minimum Tax Reporting Ordinance (MinStBV): in force since December 30, 2025.
OECD Administrative Guidance
In addition, the OECD regularly publishes Administrative Guidances.
- Clarifications on application in complex cases
- Simplifications for practical implementation
- Mechanisms for avoiding double taxation
Upcoming Obligations for Companies
- Minimum Tax Report: submission by June 30, 2026.
- Minimum Tax Return: submission by June 30, 2026.
- QDMTT and IIR Declarations Abroad: generally by June 30, 2026.
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We translate the complex regulations and current requirements of Pillar 2 into clear, actionable recommendations.
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