Tax compliance practice: Draft of the Federal Ministry of Finance letter on the income tax treatment of fund establishment costs dated 15.11.2024

The tax treatment of so-called fund establishment costs was first regulated by law with the introduction of Section 6e of the German Income Tax Act (EStG) by the 2019 Annual Tax Act (JStG). Since then, this provision has been of central importance in the private equity sector. On November 15, 2024, the BMF (Federal Ministry of Finance) published a draft BMF circular on Section 6e EStG. In his current article, Dmytro Shyshkin highlights the key points of the draft letter from the perspective of tax compliance practice.