German Annual Tax Act 2022 Includes Partial Repeal of German-Nexus IP Taxation and Introduction of Solidarity Contribution for Fossil Fuel Sector

Germany published the Annual Tax Act 2022 (JStG 2022) in the Official Gazette on 20 December 2022. The main measures include:

• A partial repeal of the controversial rules regarding the taxation of income from the rent/lease or sale of intellectual property (IP) rights registered in German registers (German-nexus IP) under Section 49 of the Income Tax Law, which includes the addition of a new provision providing that where taxable income from German-nexus IP only arises because the rights are…