The “Law for a Tax Investment Immediate Programme”, commonly referred to as the “Investment Booster,” represents a structural adjustment to the German tax code. Its primary objective is to strengthen Germany’s position as a business location by reducing the effective tax burden and improving liquidity conditions for capital-intensive companies.

For international investors, the legislation introduces two critical mechanisms: a phased reduction of the corporate income tax rate and the reintroduction of declining-balance depreciation.

1. Phased Reduction of Corporate Income Tax (Target: 2032)

The most significant component of the legislation is the revision of the Corporate Income Tax (Körperschaftsteuer).

Currently, the statutory corporate tax rate of 15 % acts as the federal baseline. The new legislation mandates a step-by-step lowering of this rate to 10 %, commencing in the coming fiscal year and concluding in 2032.

The rate will not drop to its target minimum in a single step. Instead, it will decrease in defined annual or biennial increments over the designated period.

This long-term schedule provides investors with planning security. It allows businesses to forecast a steadily declining tax expense over the next decade, thereby increasing the net present value of long-term projects initiated today. By 2032, the federal component of the tax burden will have reached a newly defined, internationally competitive low.

2. Contextualizing the Trade Tax

When calculating the total tax burden in Germany, investors must account for the Trade Tax (Gewerbesteuer). This is a municipal tax levied by local authorities to fund community infrastructure, and it varies by region (typically adding between 14% and 17% to the overall burden).

The “Investment Booster” operates exclusively at the federal level and does not abolish the Trade Tax. However, the reduction of the federal Corporate Income Tax is designed to lower the aggregate effective tax rate from (now) 30 % in the average to 25 % in the average by 2032.

3. Liquidity Management: declining-balance Depreciation

Complementing the rate reduction is a measure designed to improve immediate corporate liquidity: the reintroduction of declining-balance depreciation for movable assets.

Under standard linear depreciation, asset costs are deducted in equal amounts over the useful life of the item. In contrast, declining-balance depreciation allows companies to deduct a fixed percentage of the asset’s residual book value each year.

This method results in significantly higher deductible expenses in the early years of an asset’s lifecycle.

The Investor’s Benefit: By front-loading expenses, companies reduce their taxable income during the investment phase. This deferral of tax payments effectively functions as an interest-free liquidity bridge, freeing up capital for further reinvestment or operational ramping.

The “Investment Booster” moves away from short-term subsidies in favour of structural tax reform. By combining a predictable, long-term reduction of the Corporate Income Tax through 2032 with the immediate liquidity benefits of declining-balance depreciation, the legislation aims to align the German fiscal environment with the requirements of global capital markets.

Ralf Buchhauser, Wirtschaftsprüfer, Steuerberater und Rechtsanwalt bei Auren Deutschland in München, im Büro

Ralf Buchhauser
Certified Public Auditor (Germany), Certified Tax Advisor (Germany), Attorney
[email protected]