Apply for an exemption certificate for tax-privileged foreign investors in investment funds

Under certain conditions, tax-exempt foreign investors in investment funds can apply for an exemption certificate for the full or partial tax exemption of the investment fund.

With an exemption certificate, investment funds can prove the tax status of their tax-exempt foreign investors.

Investment funds are generally subject to corporate income tax on their

• domestic participation income,
• domestic real estate income and
• other domestic income.

With this certificate, the income from the investment fund is partially or fully tax-exempt.

As a foreign capital investor, you can apply for the exemption certificate from the Federal Central Tax Office (BZSt). You must submit the original of this certificate to your investment fund.

If you do not apply for an exemption certificate or fail to provide such a certificate to the investment fund, the investment fund's income will be subject to corporate income tax.

You can apply for the exemption certificate online or in writing by post from the Federal Central Tax Office (BZSt).

If you would like to submit the application online:

• Register in the online portal as well as for the Investment Tax Act (InvStG) – Exemption Certificate department.
• The portal guides you step by step through the application and the required documents.
• The BZSt is reviewing your application. If necessary, you may need to answer further questions or submit additional documents.
• If the BZSt approves your application, it will send you the issued exemption certificate online, provided you have not objected to this method of delivery.
  • If you have objected to electronic delivery, you will receive the certificate by mail.
• Forward your exemption certificate to the investment fund.
• The investment fund asserts your tax advantage against the tax authorities.

If you would like to submit the application by mail:

• Download the form from the Online Form Management System (FMS) of the Federal Finance Administration (BFINV).
• Fill out the application and print out the application form.
• The application form must be signed by a legal representative of the investors or their authorized agents.
• Send the form together with all required documents to the official seat of the Federal Central Tax Office (BZSt) in Bonn.
• The BZSt is reviewing your application. If necessary, you may need to answer further questions or submit additional documents.
• If the BZSt approves your application, it will send you the issued exemption certificate by mail.
  • Delivery of the exemption certificate by mail abroad is only possible if this is permissible under international law. In the case of some states, the Federal Central Tax Office (BZSt) is not permitted under international law to deliver the certificates by mail. In these cases, the specification of an authorized recipient in Germany is strictly required.
• Send your original exemption certificate by mail to the investment fund.
• The investment fund asserts your tax advantage against the tax authorities.

• Objection

Further information on how to appeal can be found in the notice regarding your application for the exemption certificate.

• lawsuit before the administrative court