No additional burdens for companies when implementing shareholder identification request (in German)

From 2025, listed companies will have to conduct a comprehensive shareholder identification query with intermediaries at the time of the profit distribution resolution. They must transmit the information obtained to the Federal Central Tax Office. We continue to view the introduction of this obligation very critically. 

In our comments on the implementation of the reporting procedure pursuant to Section 45 (9) of the German Income Tax Act (EstG), we call for no further obligations to be imposed on companies when implementing the new obligations, which would lead to additional expenses and legal risks. To this end, it must be made clear that companies are not responsible for the correctness and completeness of the data transmitted. This is imperative if only because the data does not originate from the companies.