Pillar Two Side-by-Side Package for global minimum tax agreed

Pillar Two

On 5 January 2026 the 147 countries and jurisdictions included in the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS Inclusive Framework) agreed on the main elements of a package for the Side-by-Side System in OECD global minimum taxation.

| 5 min read | 06 Feb 2026

Draft bill on the German Minimum Tax Amendment Act published

Update on minimum taxation

On 6 August 2025 the Federal Ministry of Finance (BMF) sent its draft bill on the German Minimum Tax Amendment Act (MinStAnpG) to the industry associations. The bill contains extensive amendments to the Minimum Tax Act (MinStG; Pillar 2), implements the DAC9 Directive and adds relevant provisions to the Income Tax Act (EStG) and the Foreign Tax Act (AStG). The main points are new rules to prevent avoidance strategies related to global minimum tax, abolishing the royalty deduction limitation rule and changes to the controlled foreign corporation rules.

| 3 min read | 12 Aug 2025

DAC 9 – the EU has reached agreement on the exchange of information for GloBE Information Returns (GIR) for companies subject to Pillar Two

EU creates basis for information exchange in GloBE Information Returns

On 11 March 2025 the Council reached an agreement on the exchange of information for GloBE Information Returns (GIR) for companies affected by Pillar Two. This is designed to create a Union-wide basis for the automatic exchange of information on GloBE Information Returns. For companies with Pillar Two duties, this means that in future they will be able to file their GIR centrally in only one member state. DAC9 thereby provides a substantial simplifica-tion for multinational and large German groups of companies that fall under the German Mini-mum Tax Act (MinStG).

| 3 min read | 29 Apr 2025