Pillar Two / Global Minimum Taxation

Pillar Two / Global Minimum Taxation: Certainty for International Groups

With the global minimum tax (Pillar Two), the OECD ensures an effective minimum level of taxation of 15 % for large multinational groups — implemented in Germany through the Minimum Tax Act (Mindeststeuergesetz).

The rules capture groups with consolidated revenue of €750 million or more. A foreign group of that size will therefore regularly fall within scope together with its German entities.

At the heart of the regime is the top-up tax: where the effective tax rate in a jurisdiction falls below 15 %, the shortfall is collected. In practice, the statutory administrative burden often outweighs the actual tax liability — even where no tax is due, an extensive set of calculations must be prepared and multiple reporting obligations fulfilled.

Our Pillar Two services:

• Initial analysis and impact assessment: review of the €750 million revenue threshold, identification of the constituent entities and determination of the group head
• Determination of the effective tax rate (ETR) per jurisdiction and calculation of any top-up tax amounts
• Calculation and documentation of the minimum tax provision for the consolidated financial statements (IFRS / German GAAP)
• Analysis of safe harbour provisions
• Determination of the group head and preparation of the group head notification to the Federal Central Tax Office (BZSt)
• Preparation and filing of the minimum tax return (self-assessment)
• Compilation and submission of the GloBE Information Return (GIR), including data collection from the group companies
• Ongoing advice on elections, transitional rules and structuring options

Pillar Two accompanies an investment from market entry to exit. With LOHR+COMPANY GmbH, these requirements are aligned with your vision of a legally sound and efficient investment in Germany.