Pillar 2 – Deutschland: German Implementation of the OECD’s Pillar Two — - Additional complexity without achieving the actual goal?

Key Points

• Implementation presents challenges in adhering to the EU Minimum Tax Directive, and may not achieve intended outcomes.
• Key provisions of the German Minimum Tax Act reveal complexities in execution and interpretation.
• Analysis illustrates the situation surrounding the minimum tax group under German law, highlighting its peculiarity and implications.
• Significant gaps indicate that while reforms are in place, full alignment with the OECD's objectives remains elusive.

Abstract