File a separate and uniform assessment of tax bases for foreign special investment funds

For foreign special investment funds, you must submit a declaration so that the relevant tax assessment bases can be bindingly determined for the taxation of their investors.

Investment funds are subject to corporate income tax on their

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

Special investment funds are special investment funds for institutional investors that comply with statutory investment regulations.

The Federal Central Tax Office (BZSt) generally determines the taxation bases for foreign special investment funds and their investors. Following the end of the financial year, special investment funds must prepare a return for the separate and uniform assessment and submit it to the BZSt.

The declaration for the separate and uniform assessment of foreign special investment funds must be made by:

• the domestic or foreign management company or
• the domestic investor

Note: For domestic special investment funds and foreign special investment funds whose income subject to tax in Germany is exclusively or partially not subject to withholding tax, the tax return is to be submitted to the locally competent tax office. The BZSt is only responsible for foreign special investment funds whose income subject to tax in Germany is fully subject to withholding tax or which do not generate any income subject to tax in Germany at all.

You must submit the declaration for the separate and uniform assessment of the taxation bases of foreign special investment funds in writing to the Federal Central Tax Office (BZSt).

• Download the form from the Online Form Management System (FMS) of the Federal Finance Administration (BFinV) and fill it out.
• Print out the completed application form. The application form must be signed by
  • the legal representative of the investment fund or
  • a person authorized by the legal representative.
• Send the signed form together with the other required documents by post to the BZSt headquarters in Bonn.
• The BZSt is reviewing your return. If necessary, you may need to answer further questions or submit additional documents.
• The submitted declaration is deemed to be a determination of the tax bases.
• If there are any discrepancies, the BZSt will issue a notice of change and send it to you by mail.

There are no costs.

• Objection
• Action before the finance court