KPMG Germany Webpage
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The key features of the proposed tax reform are listed below. More detail on certain items is provided by article no. 184.
- abandonment
of the current split-rate imputational system of corporate taxation, under which corporation tax paid by a distributing corporation is fully creditable to domestic dividend recipients, who include the credit amount in their income; adoption of a "classical" system under which corporate profits would be subject to a definitive, non-creditable 25 % corporation tax
- 100 % dividends-received exemption for corporations on domestic and foreign dividends, regardless of holding period, percent stake, activity requirements, or tax treaty
