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Germany Updates Guidance on Interest Deduction Limitation Rules

31 March 2025

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Approved Changes

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Germany

The German Ministry of Finance has published updated guidance (BMF Letter) on the interest deduction limitation rules ("interest barrier") considering amendments introduced by the Secondary Credit Market Promotion Act to Section 4h of the Income Tax Act (EStG) and Section 8a of the Corporate Income Tax Act (KStG), which generally apply from the 2024 assessment period. As previously reported, amendments were made in relation to the carryforward of excess interest expense, the carryforward of unused EBITDA, the various exemptions from the interest deduction limitation rules, including the addition of an exemption for public infrastructure projects, and other related matters. The...