ey-global-tax-policy-outlook-for-2015

Germany
2.4 Tax policy outlook for 2015 — detail
Corporate income taxes
• Taxation of capital gains realized on the disposition of
portfolio corporate shareholdings of less than 10% will be
reconsidered in 2015. A majority of states strongly support
such taxation. Currently, only dividends are fully taxable for
a corporate shareholder with such portfolio shareholdings,
while capital gains are effectively 95% tax exempt. It
has been announced that a draft bill will be published by
mid-2015.
• It remains to be seen whether states will enforce the
implementation of stricter anti-hybrid rules in 2015. If not,
such rules will probably be implemented as from 2016 as
a part of the wider implementation of BEPS issues. Hybrid
mismatch rules are part of the agenda of a joint federal and
state working group on early BEPS implementation that
in 2015 will discuss options to introduce BEPS legislation.
A draft bill will be announced in 2015 that will include at
least some aspects of anti-hybrid mismatch regulation.
•
optimistic that progress can be made in the CCTB discussion
CCTB, including consolidation and formulary apportionment
of the tax base.
Taxes on wages and employment
• Conservative backbenchers have started an initiative to
push a reform of the personal income tax rate which would
effectively lower personal income taxes. The background to
this issue is the progressive course of the marginal personal
of 14 percent and then rises in bands, up to highest marginal
rate 45 percent. The conservative initiative criticizes that
historically, personal income tax policies have not taken
The initiative aims to reform the income tax rate so as to
and Finance Minister Wolfgang Schäuble do not support this
initiative, but broad support in the conservative party could
put it on the tax policy agenda in 2015.
VAT, GST and sales taxes
•
quick reaction mechanism. Therefore, the extension of the
reverse charge system is expected to remain a tax policy
issue in 2015.
•
an inheritance tax law amendment will be necessary until
30 June 2016. The new coalition has committed itself to
a business-friendly adjustment, but we expect the social
democrats and the states to push for a new regulation that
increases inheritance tax revenue. Inheritance tax revenue is
part of the budget of the states.
• Concerning real estate tax, the current valuation system
is under pressure as it utilizes values from the 1930s and
1960s. It is possible that either court decisions will result
in reform, or the states and the federal level proactively will
agree on reform. Several proposals have been in discussion
for the past two years. The outcomes will likely lead to higher
real estate taxes. The federal coalition has called the states
to agree on a reform model.
•
transaction tax (FTT). Since many EU Member States oppose
that have joined an enhanced cooperation procedure. It
is expected that there will be an agreement within the
2.5 Fiscal stimulus in 2015
In reaction to the discussion on the need for higher public
has developed a program to increase federal investments from
2016 onwards. This program will cumulatively raise federal
investments by EUR10b. from 2016 to 2018. It is not clear yet
the program will not include tax components but instead will
focus on higher public expenditures.
The outlook for global tax policy in 2015 |
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