14 May 2021

Corporate Income Tax Modernisation Act – First Reading in the Bundestag on 22 April 2021

Opt-in model, internationalisation of reorganisation tax law, capital contribution solution for overpayment/underpayment of profit transfers, and new rules regarding foreign currency losses.

The so-called “Corporate Income Tax Modernisation Act” is being discussed in the ongoing legislative process. The first reading in the Bundestag was held on 22 April 2021. The “Corporate Income Tax Modernisation Act” provides an opt-in model particularly enabling commercial partnerships and partnership companies to choose tax classification as a corporation, and also further internationalises German reorganisation tax law. Partnerships interested in making use of the opt-in model should keep tabs on the legislative process so they will be able to perform a precise analysis of the change in form triggered by this option.


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Contact person

Dr. Petra Eckl


+49 69 710003-0


Dr. Dirk Koch


+49 89 288174-676


Dominik Berka

Local Partner*

+49 69 710003-194


Felix Schill, LL.M.


+49 69 710003-199


Stephan Wachsmuth, LL.M.


+49 89 288174-676


For reasons of better readability, we use the gender-neutral generic masculine. However, the information expressly refers to all genders.

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