Germany: Registering Pillar Two minimum tax group leader

The German Ministry of Finance has published a notification form (German) for registering the minimum tax group leader with the German tax authorities for Pillar Two purposes. This form centralizes top-up tax payments and filing obligations at the level of a single German-based constituent entity (i.e., minimum tax group leader).

Determining the minimum tax group leader

The German tax authorities rely on the following order:

• The ultimate parent entity (UPE) if it is tax resident in Germany
• The parent company located in Germany that is the common parent of all German constituent entities if the UPE is not tax resident in Germany
• The constituent entity designated by the UPE in other cases
• The economically most significant German entity if no entity is designated by the UPE

Submission requirements

The minimum tax group leader must submit information electronically to the German Federal Central Tax Office (BZSt) via their online portal, including:

• Identification of the UPE and the minimum tax group leader (e.g., name, address, email, tax number, contact person)
• Characterization of the minimum tax group leader (UPE, domestic parent entity, designated entity, economically most significant entity)
• Information on the filing representative or tax advisor authorized to submit the notification (if any)

According to the amendment to the law recently passed by the Bundestag on October 18, 2024 (Annual Tax Act), a constituent entity would automatically be considered the minimum tax group leader and thus, needs to file the respective notification.

Key deadlines

• The notification is due within two months after the end of the calendar year in which the group falls under the German Pillar Two rules. For calendar year taxpayers, the deadline is February 28, 2025.
• If the financial year differs from the calendar year, the deadline is February 28, 2026, with exceptions for short financial years ending before January 1, 2025.

Implementation

Electronic filing will be available starting January 2, 2025.
 

Read an October 2024 report prepared by the KPMG member firm in Germany