Buchveröffentlichungen

Tax expenditures country report: Germany

Thöne, Michael / Christian von Haldenwang
Buchveröffentlichungen (2026)

Bonn/Zürich: German Institute of Development and Sustainability (IDOS) und Council on Economic Policies (CEP)

DOI: https://doi.org/10.23661/cr5.2026

Tax expenditures (TEs) in Germany represent a significant portion of government spending, amounting to 1.7 percent of GDP in 2026. Over the last decade, revenue forgone reported by the German federal government has remained consistently below 2.0 percent of GDP. This is below the global average of 4.0 percent of GDP (see Redonda, von Haldenwang, & Aliu, 2026), and less than most of Germany’s neighbours. However, it is important to note that official TE reporting is incomplete, as acknowledged by the German Federal Ministry of Finance (BMF) itself.
Recent changes in TE use have been motivated above all by three rationales: First, TEs have been employed as primary crisis response measures, mainly in the context of the Covid-19 pandemic, the Russian war on Ukraine and the US-Iran war. Second, they are used to promote the transition towards zero carbon of the German energy system, including housing, transportation and manufacturing. Third, TEs are granted to promote growth or compensate high energy costs.
Since 1967, Germany reports on tax expenditures (TEs) and direct subsidies under the Act to Promote Economic Stability and Growth (“Stability and Growth Act”). Reporting covers all provisions that have an economic objective. The “Subsidy Report” is submitted to parliament every second year, with the most recent one (number 30) published in September 2025 (BMF, 2025). By law, the report should be submitted to parliament “together” with the government draft for the federal budget of the coming year, but usually the report trails the draft budget for several weeks, sometimes even months. As previous editions, the 30th Subsidy Report contains two lists of TEs. One (“Annex 2”) presents 107 TEs that fall under the reporting mandate of the Stability and Growth Act. The other one (“Annex 3”) lists 52 provisions that result in revenue forgone, but do not fall under the mandate of the subsidy report as such, though the distinction between both lists is not fully consistent. Also, just 72 out of the 107 TEs presented in Annex 2 and only 18 of the 52 provisions listed in Annex 3 come with revenue forgone estimates. Based on the federal government’s budget draft for 2027, the quantified TEs of Annexes 2 and 3 amount to 76.5 billion Euro in 2026 (after 74.3 billion Euro in 2025).
Annex 2 provisions are presented in great detail, each with its own data sheet. This reporting practice has earned Germany a relatively high score on the Global Tax Expenditures Transparency Index, where it ranks 6th out of 116 assessed countries (Redonda et al., 2026). In contrast, Annex 3 provisions are presented in one single list with much less information. In addition, multiple provisions that would technically qualify as TEs are not reported at all. As a result, it is almost impossible for political decision-makers and the public in general to gain a complete overview of all the TEs in use, their fiscal cost and the impacts they have. Inconsistent reporting is partly due to the lack of a well-defined tax benchmark system, complicating the identification of TEs and estimations of revenue forgone. The criteria applied to decide whether a specific provision is a TE or part of the benchmark tax system are not always clear. For instance, lower value added tax (VAT) rates for food are part of Germany’s benchmark system and not reported, while lower VAT rates for cultural activities are considered a TE.
The federal subsidy guidelines, issued in 2006 and amended in 2015, ask for a regular evaluation of all subsidies in use. Against this backdrop, two major rounds of evaluations have been commissioned by the BMF. The first round in 2007-2009 covered roughly the biggest 20 TEs listed in the subsidy report. Together, these TEs resulted in revenue forgone of 18.1 billion Euro per year (Thöne et al., 2009). To the best of our knowledge, at the time this was the biggest evaluation of tax expenditures ever conducted worldwide. Ten years later, 2017-2019, a second round of evaluations was commissioned, which was meant to cover the next twenty largest TEs plus several closely related smaller TEs, increasing the total coverage of this evaluation round to 33 measures with revenue forgone of 7.4 billion Euro per year (Thöne & Gerhards, 2019). Even with these two rounds of evaluations, however, the federal government has not fully lived up to the principles it is supposed to follow. 50 out of the 107 TEs listed in Annex 2 of the 30th Subsidy Report, representing over a third (34 percent) of the revenue forgone, have never been evaluated. The figure rises to 66 percent when the provisions listed in Annex 3 of the report are included, as these are not subject to regular evaluations. As an additional point, only 17 out of 107 TEs come with a time limit and only two TEs are granted with decreasing benefits over time. TEs play an important role in German environmental and climate policy. On the one hand, they are used as environmental TEs (ETEs) to advance environmental protection and climate policy, above all in mobility, energy and heating. Revenue forgone from ETEs in 2026 amounted to 5.8 billion Euro. On the other hand, TEs are the dominant form of environmentally harmful subsidies. According to a report published by the German Federal Environment Agency (UBA), they resulted in 48.4 billion Euro of revenue forgone in 2018 (Burger & Bretschneider, 2022). A new report published bei the Bertelsmann Foundation focuses specifically on subsidies that are harmful to the climate (Fiedler et al., 2026). It shows that TEs falling under this category generated revenue forgone in the range of 47.3 billion Euro in 2024, including 18,2 billion Euro classified as only “partially harmful”. Sustainability was introduced as an aspect of TE reporting in 2015, understood as a broad concept that combines economic performance, the preservation of natural resources and social cohesion from a long-term development perspective. This is in line with the common worldwide understanding of sustainability and implies that the evaluation score obtained by each TE in this category may reflect very different properties, not only environmental or climate-related ones. In fact, the 30th Subsidy Report lists 15 cases where TEs are meant to support the preservation of natural resources, against 36 cases where the aim is social cohesion and 93 cases that point at economic sustainability. All in all, Germany has been slow in reforming its TE regime. As a recurrent observation, the Federal Court of Auditors highlights that the government has done too little to follow up on the recommendations that came out of the various evaluations since 2009. Against this background, three actions seem to be particularly relevant. To start, the federal government needs to address the lack of clarity regarding the German benchmark tax system. A comprehensive stock-taking review could help to determine which provisions should be classified as “structural” parts of the benchmark system, and which are “non-structural” and thus to be considered TEs and reported in future subsidy reports. In the medium term, this initiative could result in TEs no longer being viewed exclusively within the context of economic objectives, but encompassing social and other policy goals as well. This would be in line with international good practice in TE reporting. Consistent with these standards, TE reports should also be submitted to and adopted by parliament as an integral part of the annual budget. In addition, a clear evaluation framework with regular intervals and broad coverage should be implemented.