Germany Amending Minimum Tax Law to Implement BEPS Inclusive Framework Administrative Guidelines on CbC Safe Harbor and Other Matters

The German Ministry of Finance has published a discussion draft of a draft law to amend the Law implementing Council Directive (EU) 2022/2523 on ensuring a global minimum level of taxation. The Ministry notes that the BEPS Inclusive Framework issued two new administrative guidelines in December 2023 and June 2024, which require an adjustment of the minimum tax law. Germany has committed to implementing such administrative guidelines within 24 months of publication.

Although the June 2024 g…