Germany: Annual Tax Act 2024 passed by lower house of Parliament includes Pillar Two changes, other tax developments
Recent tax developments in Germany
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October 31, 2024
The lower house of Parliament (Bundestag) on October 18, 2024, passed the Annual Tax Act 2024, which includes primarily technical amendments related to:
- Restructuring and reorganizations
- Controlled foreign company (CFC) taxation
- Pillar Two global minimum tax rules
- New minimum tax group rules
- Implementation of GIoBE model rules with regard to mobile employees
- Real estate
- Capital income/withholding tax
- Tax procedures
The next step in the legislative process would be approval of the bill by the upper house of Parliament (Bundesrat), which could take place in the November meeting on November 22, 2024.
Read a November 2024 report prepared by the KPMG member firm in Germany
Other recent tax developments in Germany include:
- Promulgation of Fourth Bureaucracy Relief Act, which includes certain tax-related measures including inclusion of the so-called transaction matrix as a new component of required transfer pricing documentation
- Amendment of the Regulation to Apply the Act to Combat Tax Avoidance and Unfair Tax Competition to reflect the current status of the EU “blacklist”
- Notification of the OECD that domestic measures to modify seven German income tax treaties for implementation of the BEPS Multilateral Instrument (MLI) have been completed
- Publication of notification form for registering the minimum tax group leader with the German tax authorities for Pillar Two purposes (read TaxNewsFlash)