Germany: Legislation increasing maximum amount for roll-over of hidden reserves in corporation shares enacted; other tax developments
Act to Promote Private Investment and Germany as a Financial Centre promulgated on February 9, 2026.
The Act to Promote Private Investment and Germany as a Financial Centre, which was promulgated on February 9, 2026, increased the maximum amount for the roll-over of realized hidden reserves from the sale of shares in corporations held as business assets, to preferential reinvestment assets (e.g., shares in corporations or buildings), from €500,000 to €2 million, appliable to capital gains arising in financial years beginning after February 9, 2026.
Other recent tax developments in Germany include:
- Current Federal Tax Court decision on employee share ownership schemes
- Lower Tax Court of Berlin-Brandenburg (10 K 10106/23): Crediting foreign withholding tax against domestic trade tax
- Federal Ministry of Finance: Draft guidance on tax authorities’ principles for concept of permanent establishments (PEs)
Read a March 2026 report prepared by the KPMG member firm in Germany