Global Minimum Tax: BDO Analyzes Regulatory Developments
International companies with revenues exceeding EUR 750 million must adhere to a global 15% minimum tax. In Germany, the law took effect on January 1, 2024.
Tax advisory firm BDO AG has issued an analysis of the developments and implications of the global minimum tax, known as Pillar 2.
The new tax regime mandates that multinational enterprises with revenues of at least EUR 750 million pay an effective tax rate of 15% on their profits, regardless of their country of incorporation. Germany implemented its domestic minimum tax law on January 1, 2024, requiring local companies to comply with these new requirements.
BDO notes that Pillar 2 remains a significant topic in both national and international political discussions. However, potential U.S. countermeasures, termed "Revenge Tax," have been averted through a joint G7 declaration. The OECD has since finalized the regulations, and Germany enacted legislative adjustments in December 2025 with the "Mindeststeueranpassungsgesetz" (MinStAnpG) law.
The German law introduces substantial changes, particularly relevant for international family businesses and corporations. Reporting packages can now serve as a qualified data source for calculating both Transitional Safe Harbour rules and the Full GlobE Calculation, thereby simplifying the process for companies.
Furthermore, the law includes new anti-abuse provisions aimed at preventing tax avoidance, especially through state measures that facilitate the recognition of deferred taxes. An attempt has also been made to include a provision allowing for the recognition of active deferred taxes for Pillar 2 calculations, though the interpretation based on the current legislative wording remains unclear.