Abolition of the requirement to report exempt capital income (MURI reporting)

Background: Withholding tax on capital income

In Germany, open and hidden profit distributions from domestic companies are generally subject to withholding tax at a rate of 25%, plus a solidarity surcharge of 5.5%. This applies irrespective of whether the distribution is made to a domestic or foreign shareholder.
Recipients or beneficial owners who are resident abroad may be eligible for a full or partial exemption from German withholding tax, provided the relevant statutory requirements are met, based on an applicable double tax treaty or EU directive (§§ 50c, 50d (3) German Income Tax Act – EStG).

Relief may be granted by either refunding tax already withheld or exempting future payments from withholding during the exemption certificate’s validity period (from 1 January 2025 for a maximum of five years). However, this certificate does not exempt the taxpayer from the obligation to file a tax return.

Previous legal situation: MURI reporting as an additional condition

Where an exemption certificate had been issued by the German Federal Central Tax Office (Bundeszentralamt für Steuern – BZSt), it regularly included the condition that the income distributed and exempted during the calendar year had to be reported to the BZSt by 31 May the following year via a MURI notification. This reporting obligation also applied in cases where no distributions were made, requiring the submission of nil notifications.

Current development: Revocation of the reporting obligation

This reporting obligation has now been revoked by a general administrative act dated 30 March 2026, which was published on the BZSt website on 15 April 2026. Consequently, the general obligation to submit a MURI notification no longer applies with respect to capital income accrued in the calendar year 2025 (previously due by 31 May 2026) or to future periods. This also applies in cases where a certificate of exemption from German withholding tax still contains such a condition. The general administrative act provides only one limited exception, which does not apply to capital income from pooled or segregated custody shares.

Further details are available in the BZSt’s official notice and the published general administrative act.

What remains unchanged?

The revocation of the reporting obligation does not affect the substantive requirements for withholding tax relief. In particular, the existing rules governing applications for exemption certificates and withholding tax refunds under double taxation treaties and EU directives remain fully applicable.

Despite simplification, complexity remains

The revocation of the requirement to submit capital income exempt from German withholding tax represents a welcome reduction in administrative burden. Nevertheless, careful planning and compliance are still essential for cross border profit distributions to ensure proper withholding tax relief and avoid tax risks.

We continue to support you in all matters relating to withholding tax on capital income, exemption and refund procedures, and planned distributions to foreign shareholders.