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Who has to pay corporate income tax?

If the management or the registered office is located in Germany, they are subject to unlimited corporate income tax:

  • Corporations (e.g. GmbH, AG) as well as opting companies within the meaning of § 1a KStG
  • Cooperatives
  • Mutual insurance companies
  • other legal entities under private law (e.g. associations, foundations)
  • associations, institutions, foundations and other special-purpose assets under private law with no legal capacity, and
  • Commercial operations of legal persons under public law (e.g. economic activities of municipalities).

All income is subject to tax.

Companies with limited tax liability are those which have domestic income but which in Germany

  • neither a management
  • nor have a registered office in Germany.

Only domestic income is taxable.

The place of management is the place where the relevant business decisions are made. The registered office of the company is determined by the partners in the articles of association and entered in the commercial register.


Non-profit associations only have to pay corporation tax on income from their business operations if their income exceeds € 5,000.

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