German tax reform

09.09.2024

Bundeszentralamt für Steuern (BZSt, German Federal Central Tax Office) has revised regulations related to relieving foreign taxpayers from withholding taxes. In addition to the digitalisation of the process, particular attention has been paid to eliminating risk factors that could lead to unjustified relief.

Withholding tax reform: German Withholding Tax Relief Modernisation Act1

The reform has the following impact on Clearstream and its clients.

  • Withholding tax agent reporting requirements for income distributed: The withholding tax agent is required to electronically notify BZSt when processing tax voucher requests and payments of the capital gains tax for income due from 1 January 2026.
  • Data supply along the custody chain: Clients must provide Clearstream with all relevant information that is not available for Clearstream as a withholding tax agent. This includes holding breakdowns, trading histories and information about the custody chain.
  • Digitisation: Clearstream will issue electronic tax certificates with a Universally Unique Identifier (UUID) that identifies the client request filed with BZSt.
  • Refunds: Under the reform, tax refunds can only be filed with the UUID of a successfully submitted electronic tax certificate. This aligns with the requirement for online submissions implemented in 2023 (see the “Client announcements” section below).

The changes enacted by the law will take effect on 1 January 2026. 

Client announcements

The table below provides an overview of the client announcements regarding the upcoming changes to ClearstreamXact. It will be updated with further details as they become available.

CBF accounts

CBL or CBF-i accounts

LuxCSD accounts

Announcements

C23010: Update for electronic transfer of refund applications for taxpayers with restricted tax liability

L24029: German Tax Reform: ClearstreamXact enhanced tax functionality – Update

 

D24034: German Tax Reform: ClearstreamXact enhanced tax functionality

C24037: German Tax Reform: ClearstreamXact enhanced tax functionality 

Further information

For further information about announcements, please contact the Clearstream Connectivity Helpdesk or your Relationship Officer.

For further information about this page or the German tax reform, please contact germantaxreform@clearstream.com.

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1. Abzugsteuerentlastungsmodernisierungsgesetz – AbzStEntModG