Germany: Draft amendments to Pillar Two rules adopted by Federal Cabinet; draft bill to implement DAC8; other tax developments

Draft amendments to Pillar Two rules would implement OECD guidance

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September 30, 2025

The Federal Cabinet on September 3, 2025, adopted a draft bill providing for amendments to the Minimum Tax Act, largely in line with the draft published by the Ministry of Finance in August 2025. Read TaxNewsFlash

The amendments aim to implement new OECD Administrative Guidance items from December 15, 2023, May 24, 2024, and January 13, 2025, and simplify individual anti-profit shifting regulations to avoid bureaucracy.

Other recent tax developments in Germany include:

  • Government draft bill to promote private investment and Germany as a financial center
  • Government draft bill to Implement DAC8
  • Draft bill to amend tax regulations relating to Lithuania income tax treaty, FATCA, and permanent establishment profit allocation
  • Federal Tax Court (XI R 15/23): E-Mails as business letters to be submitted in the context of an external tax audit; digital documents on group transfer pricing as tax-relevant documents

Read an October 2025 report prepared by the KPMG member firm in Germany

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