German tax reform
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.
The dates have been amended based on the "Jahressteuergesetz 2024" which passed the Bundesrat (2nd chamber) on 22 November 2024. The newly introduced law has the effect to postpone the implementation of the German withholding tax relief reform to 1 January 2027.
Withholding tax reform: German Withholding Tax Relief Modernisation Act1
The act 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 2027.
- 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 2027.
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.
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