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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.

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.

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).

The new U.S. President, Donald Trump, has already started implementing key campaign promises in the early weeks of his second term. This includes a shift away from the tax policies of his predecessor. In this article, we explore what this change in tax policy means for globally operating companies, particularly regarding the implementation of the global minimum tax.

In a surprise move as part of the third relief package, the federal government decided to begin implementation of internationally agreed global minimum tax on the national level now. This once more increases the relevance for German businesses coming with the scope of Pillar Two to get themselves prepared.

Many questions still remain unanswered in regulating how global minimum tax is to be implemented. Our update on the current situation of Pillar Two and an assessment of further developments.