Choosing a tax-friendly post-Brexit location - Germany

Tax attractiveness is a key factor in Brexit relocation.

France, Germany and Luxembourg are often considered as potential post-Brexit locations, and each country has taken steps to appeal to UK companies in the banking, financial and insurance sectors.

Germany’s tax rates are not particularly low. Its attractiveness from a tax standpoint therefore lies in the various allowances available to reduce the tax basis. For companies, the business profits tax rate ranges between 30% and 32%, depending on the municipality where the company pays its trade tax (Gewerbesteuer).

But this high tax rate may only apply to a small portion of a company’s profit, and the tax basis can be reduced through various allowances, including:

• depreciation of goodwill is allowed over a minimum 15-year period.
• specific accruals and reserves are available for insurance companies and pension funds.
• dividend income and capital gains deriving from disposal of shares are exempt under the participation regime. 

Individuals

For individuals, Germany’s tax rates are relatively high, with a progressively increasing tax rate that reaches around 47.5 % (including the solidarity surcharge). This scale is comparable to French rates and, as in France, financial income (income, dividends, capital gains) benefits from flat rate taxation of around 26.4%. Unlike France, however, Germany has no incentive regime for inpatriates.

Companies

Germany’s tax attractiveness is not based on its taxation rates. Its advantages lie in the security and the stability of its rules, and various possibilities for companies to reduce their tax basis, particularly in the financial and insurance industries.