German minimum tax joins mutual assistance treaty scope on 1 December

On 25 August 2026 the Federal Republic of Germany lodged a supplementary declaration with the Secretary General of the Council of Europe, in his capacity as depositary of the Convention on Mutual Administrative Assistance in Tax Matters of 25 January 1988 as amended by the Protocol of 27 May 2010Bund. The declaration amends the German notification of covered taxes under Article 2(3) of the ConventionBund by adding a new tax falling under Article 2(1)(a)(i): "Mindeststeuer"Bund. It takes effect on 1 December 2026Bund. Germany ratified the Convention, in its Protocol-amended form, by depositing its instrument of ratification with the Secretary General of the OECD on 28 August 2015, and at ratification it filed a notification of the taxes to which the Convention applies for Germany. The declaration states that Germany has since enacted domestic legislation implementing the global minimum tax, and the Foreign Minister, Dr. Johann Wadephul, declares the addition after reviewing that notification.

In Germany the global minimum tax (Pillar 2) has applied since 2024 to large groups with consolidated revenues of at least 750 million euro, and is designed to secure an effective minimum taxation of 15 per cent. It is implemented through the Mindeststeuergesetz (MinStG) on the basis of the EU minimum taxation directive, and the minimum tax applies as a standalone tax on income alongside income tax and corporation tax. The groups concerned form a minimum tax group (Mindeststeuergruppe) whose group parent (Gruppenträger) owes the tax, and they transmit the group parent notification, the minimum tax report and the minimum tax return electronically. Adding the Mindeststeuer to the taxes covered by the Convention means that mutual administrative assistance between Germany and the other Convention parties — exchange of information, assistance in recovery and related cooperation — now extends to this tax under the Convention's framework.

Separately, the same notice states that the Convention, in its Protocol-amended form, will enter into force for Zimbabwe on 1 December 2026Bund under Article 28(3) of the Convention in conjunction with Article IX(3) of the Protocol, in accordance with declarations on Annexes A and B made when depositing its instrument of ratification. The notice follows the announcement of 25 August 2026 (BGBl. 2026 II No. 178). Reservations and declarations on the Convention and the amending Protocol, other than Germany's, are not published in the Bundesgesetzblatt Teil II; like the information on Annexes A, B and C, they are available in English and French on the Council of Europe's website.

The notice is dated 22 September 2026, issued in Berlin by the Federal Foreign Office on behalf of the Federal Minister for Foreign Affairs, and published as Bundesgesetzblatt 2026 Part II No. 214, issued in Bonn on 25 September 2026.

Legal basis: Bekanntmachung über den Geltungsbereich des Übereinkommens über die gegenseitige Amtshilfe in Steuersachen in seiner geänderten Fassung vom 22. September 2026 (BGBl. 2026 II Nr. 214), covering the declaration under Article 2(3) of the Convention of 25 January 1988 as amended by the Protocol of 27 May 2010 (BGBl. 2015 II S. 966, 967, 986) and the entry into force for Zimbabwe under Article 28(3) of the Convention in conjunction with Article IX(3) of the Protocol.