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An overview by Flick Gocke Schaumburg, Taxand Germany
Under Germany’s new Minimum Tax Act (MinStG), corporate groups subject to the global minimum tax (Pillar Two) must designate a Minimum Tax Group Head to centralise filing and payment responsibilities for domestic and foreign entities. The official notification form must be submitted electronically by 28 February 2025.
The determination of the Group Head follows a top-down approach. If the Ultimate Parent Entity is based in Germany, it assumes the role; otherwise, the most significant German entity or an entity assigned by the Parent Entity takes responsibility. The Group Head is required to notify any changes or revocations promptly.
Dr. Georg Bestelmeyer, Dr. Alexander Geißler and Dr. Nils Linnemann from our German member firm Flick Gocke Schaumburg have analysed this change in further detail here.
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