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Germany approves changes to interest deduction limits: PwC

Germany approves changes to interest deduction limits: PwC

 


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What happened?

The German Bundesrat (Federal Council) passed the Growth Opportunities Act on 22 March. The legislative action introduces an investment grant for certain investments aimed at achieving energy savings and makes various adjustments to the provisions of national and international tax legislation. This tax overview focuses on the important changes regarding the rules limiting the deduction of interest and the changes to the German minimum taxation rules.

Why is it relevant?

The act includes changes in the rules for determining the equal price for financing relations between companies. These new rules apply from the tax assessment period 2024 onwards. The law also expands the minimum taxation rules for income tax purposes by making the deduction of a carried forward loss unlimited for income below EUR 1 million and 70% for income exceeding EUR 1 million. This rule applies to assessment periods beginning in 2024 and ending in 2027.

Actions to consider

Multinational companies should review and evaluate their respective financing and group structures based on the new rules on interest deduction and minimum tax.

Sources

1/ https://Google.com/

2/ https://www.pwc.com/us/en/services/tax/library/germany-enacts-changes-to-interest-deduction-limitations.html

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