23. March 2026
Finally – bureaucracy reduction is coming after all: Passive foreign income taxation for small holdings in private equity funds abolished (Section 13 Foreign Tax Act)
Private equity investors have come to know it through painful experience – Section 13 Foreign Tax Act (Außensteuergesetz “AStG”). According to this provision, so-called interim income of a capital investment nature, in particular interest income, had to be declared separately.
18. February 2026
All’s well that ends well, or a never-ending story? FINAL BMF Circular on the capitalisation of fund establishment costs in accordance with Section 6e EStG
With Section 6e EStG, the legislator has for the first time expressly regulated a long-disputed issue – the income tax classification of so-called fund establishment costs. The provision was based on earlier case law on contractual networks, which was intended to prevent abuse, and the so-called "Bauherrenerlasse" (building contractor decrees) of the time, most recently adopted in the 2003 fund decree.
