Section 75 of the Mindeststeuergesetz requires the German entities concerned to submit the minimum tax report to the BZSt. One entity may report for the group's other German entities. This centralisation does not, however, mean that the obligation is satisfied before filing actually takes place.
Relief based on a foreign filing requires, in particular, that the ultimate parent or designated entity has filed the report in an EU Member State or a jurisdiction with the required exchange agreement with Germany for the financial year concerned. An internal group mandate alone is therefore insufficient.
It is therefore useful for the group to identify the filing entity, the chosen jurisdiction and the expected proof of transmission. Internal circulation of a preparatory file does not replace that proof. Monitoring arrangements should also enable German entities to be informed of a failure by the intended filer. The remaining question concerns the filing actually made and the applicable exchange agreement, rather than merely the contractual allocation of tasks.
The statutory deadline is fifteen months after year-end, extended to eighteen months for the first financial year, with no deadline earlier than 30 June 2026. If the expected filing by another entity has not been made, the legislation requires submission within one month of learning of that failure.