para. | paragraph

AfA | Decommissioning for Wear

BGBl. | Federal Law Gazette

or | or

EStG | Income Tax Act

Et al. | Et alia ("and others")

f. | following

ff. | following

according to

grds. | in principle

IAB | Investment deduction amount

i.H.v. | in the amount of

i.S.d. | in the sense of

JStG | Annual Tax Act

KStG | Corporate Tax Act

max. | maximum

min. | at least

No | Number

o.g. | mentioned above

paragraph | recital

Rz | Margin

S. | sentence

so-called | so-called

StÄndG | Tax Amendment Act

StEntlG | Tax Relief Act

among others | among others

UntStRefG | Corporate Tax Reform Act

from

for example | for example

cit. | quoted

Brandis, Peter/Heuermann, Bernd | Income tax law, EStG commentary, 162. 2022 edition, Munich (quote: Brandis/Heuermann – Brandis),

EStG § 7g paragraph 65.

Egner, Thomas/Stößel, Johannes | Investment deduction amount and special depreciation according to § 7g EStG, NWB Grund of 06.02.2022

(quote: Egner/Stößel, NWB Grundlagen v. 06.02.2022, paragraphs 1f, 23f, 34, 41ff, 49, 50, 58, 59f, 62, 64, 67)

Frotscher, Gerrit/Geurts, Matthias | EStG commentary, as of 04.07.2022, Freiburg

(quote: Frotscher/Geurts – Kratzsch, EStG § 7g Rz 1, 2, 23, 59, 91.)

Güldenstern, Pia | § 7g EStG – Annual Tax Act 2020 and special features during the Corona Pandemic, STFAN No. 4 of 10.04.2022, page 14 (cited: Güldenstern, STFAN 4/2022, 14, 17.)

Leingärtner, Wilhelm/Zaisch, Horst | Taxation of farmers comment, 42. 2022, Munich (quote: Leingärtner/Zaisch – Wendt, chapter 30). deductions and depreciation;

paragraph 70

Littmann, Eberhard/Bitz, Horst/Pust, Hartmut | EStG-Kommentar, Stand 01.12.2021, Stuttgart (quote: Littmann/Bitz/Pust – Handzik, EStG § 7g paragraph 69f.)

Meinert, Julian/Heeke, Jonas | Current practical questions on the investment deduction amount according to § 7g EStG, NWB No. 29 of 23.07.2021, page 2139 (quote: Meinert/Heeke – NWB No. 29 of 23.07.2021, 2139, 2145).

Schmidt, Ludwig | EStG-Kommentar, 41. Edition 2022, Munich (quote: Schmidt – Kulosa, EStG § 7g Rn 50, 67).

The investment deduction amount according to § 7g EStG is intended to make it easier for small and medium-sized enterprises to reinvest their profits. This involves in particular investments in movable assets, i.e. above all in plants and machinery. However, the investment deduction is subject to a number of conditions. On the one hand, this includes personal requirements of the respective taxpayers. Furthermore, income tax law also sets operating conditions for the investment deduction amount. And the beneficiary assets, which can be financed via an investment deduction amount, are also regulated. In addition, rules on the maximum amount, deadlines and many other details apply.

§ 7g EStG is a tax law standard that has existed for many years and enables small and medium-sized enterprises to set up and use investment deductions and special depreciations. A tax reduction resulting therefrom is linked to certain prerequisites, which are each illustrated in the following domestic work.

At the beginning of this work, general information and facts on the legal norm of § 7g EStG are examined. Here, its legal development is discussed, as well as the changes in the context of the corona pandemic and the general purpose of the standard are presented.

In the further course, the individual requirements of § 7g EStG are explained, which extend from personal to operational to formal requirements. Subsequently, the consequences of the use of an IAB are investigated, starting with the effects in the year of the formation of an IAB, thus considering the effects in the investment year and finally the consequences in the case of reversal.

Consequently, the regulations for special depreciation acc. § 7g Abs. 5 and 6 EStG.

Finally, a conclusion is made in which the results of this housework are finally summarized.

The legal standard of § 7g EStG was first introduced in 1984, within the framework of the StEntlG 1984 of 22.12.1983[1], with the aim of facilitating the financing of investments for small and medium-sized enterprises and thereby making them more competitive. [2] The scheme has since undergone several major changes. The first significant change was made by the UntStRefG 2008 of 14.08.2007[3], by which the so-called "StStRefG", which was in force until then, was amended. depreciation of savings was replaced by the investment deduction amount. Accordingly, up to 40% of the expected acquisition or production costs of a movable asset of the fixed assets could be claimed off-balance-sheet in a profit-reducing manner, provided the asset is at least. 90% operationally used and acquired or manufactured within three years. [4] A further significant change was subsequently made within the framework of the StÄndG 2015 of 02.11.2015[5]. In order to simplify the use of an IAB and reduce bureaucracy, this amendment removed the obligation to indicate the intended function of the asset to be purchased. [6]

The start of the Corona pandemic in 2020 has hit many companies particularly hard financially. In order to relieve this burden, the JStG 2020[7] amended § 7g EStG in favour of companies. The level of possible formation of an IAB has been increased to up to 50% of the expected acquisition or production costs. In addition, the investment period was extended from three to four years and the scope was also extended to leased movable assets of the fixed assets. These changes apply to all IABs formed after 31 December 2019. [] 8]

§ 7g EStG was introduced with the aim of improving the competitive situation of small and medium-sized enterprises and strengthening their investment and innovation power. Their liquidity and capital formation will also be supported by the formation of IAB. The financing of investments is also to be facilitated due to tax deferrals incurred by IAB, since the use of IAB creates an advance transfer of depreciation potential into a marketing year before acquisition or manufacture. [] 9]

Entitlements are eligible according to § 7g Abs. 1 S. 1 grds. ‘taxable person’; Restrictions to this term are not met in the legal norm, so it must be taxable persons i.S.d. EStG and KStG, who can be taxable both unlimited and limited. However, since the formation of an IAB is limited to movable assets, inevitably only those persons who have fixed assets can be eligible. These are those who receive income from the so-called profit income types according to §§ 13, 15 or 18 EStG. [] 10]

according to § 7g para. 7 S. 1 EStG are equally entitled partnerships and communities. As a company, they replace the taxpayer.

An exception to the above-mentioned beneficiaries are taxpayers who have ceased their active business activity. Due to the fact that they no longer actively participate in economic life, they are not entitled to take advantage of the tax benefits according to § 7g EStG. [11] However, this does not apply to business splits. In this case, the holding company continues to participate in economic transport through the operating company, so that both companies grds. are eligible. [] 12]

Even in the title of § 7g EStG, the legislature limits the formation of IAB to small and medium-sized enterprises. However, a corresponding definition of the term “operation” is omitted.

Grds. § 7g EStG is an operational regulation and must be examined for each individual company, not for a company network as a whole. The term “operation” is thus to be seen as an organizational unit. This is an organizational combination of personnel, material and other means of work into an independent unit, is involved in economic traffic and generates income from the types of profits as defined in §§ 13, 15 or 18 EStG.[13]

For the determination of the operating variables “small” or “medium” there is also no definition in § 7g EStG. Since the JStG 2020[14], these can only be determined on the basis of a uniform profit limit of € 200.00.00, which applies to all types of income. Condition according to § 7g Abs. 1 S. 2 No. 1 EStG is that the profit is determined in accordance with the provisions of §§ 4 or 5 EStG. [] 15)

The reason for the unification of the profit limit for all types of income was the creation of a delimitation criterion that is more targeted in practice and can be applied without special administrative effort. For IABs that were formed until 31 December 2019, differentiated operating size characteristics applied. For income from §§ 15 and 18 EStG, where the profit according to § 4 para. 1 EStG or § 5 EStG, an operating capital limit of € 235.000.00 applied. For enterprises in agriculture and forestry (§ 13 EStG) an economic value limit of € 125.000,00[17] applied, while for revenue surplus calculators whose profit according to § 4 para. 3 EStG, a profit limit of € 100,000.00 applied. [] 18)

2.3.1. Useable movable assets of fixed assets

§ 7g Abs. 1 S. 1 EStG favours usable movable assets of fixed assets. The requirement of mobility is fulfilled if the asset is not related to land or land, buildings or separate parts of buildings in a uniform use and function. This includes immovable and intangible assets grds. Off. Beneficiaries are also used and since the JStG 2020[19] also rented assets. The asset is to be allocated as a fixed asset to the fixed assets if it serves the company permanently. Since the legal standard explicitly requires an acquisition or production, an asset acquired free of charge, transferred from private assets to operating assets, transferred from working capital to fixed assets or transferred from special assets to total assets (or vice versa) is not favoured. [] 20]

2.3.2. Operational use

according to § 7g para. 1 S. 1 EStG, the formation of an IAB for a previously described economic good is only possible if it is used exclusively or almost exclusively for operation. “Exclusively” means 100% operational use, while the terms “almost exclusively” mean operational use of at least 100%. 90% or a private use of a maximum of 10%. Falling below the 90% limit or exceeding the 10% limit is harmful and leads to no IAB being formed. The scope of operational use is limited to the period between acquisition and purchase. production to be checked by the end of the marketing year following the year of acquisition or production. [] 21]

2.4.1. Maximum amount

If the aforementioned conditions are met, the formation of an IAB is possible up to a maximum of 50% (up to 40% by 31 December 2019) of the expected acquisition or production costs of the respective beneficiary economic asset. The 50% limit thus represents an upper limit by which the taxable person obtains the right to choose the amount with which he wishes to use the IAB in the respective marketing year. The use of the IAB can also be spread over several marketing years and does not have to be fully declared in the first deduction year. [] 22]

However, the sum of the IAB used in the deduction year and the three previous marketing years is acc. § 7g Abs. 1 S. 4 EStG limited to € 200,000.00 per holding. For this purpose, the total hand and special assets in partnerships must be taken into account together accordingly. [] 23]

2.4.2. Investment intention and deadline

For IABs declared until 31 December 2015, taxpayers were obliged to notify the tax office of the foreseeable function of the asset and the amount of its planned acquisition or production costs.[24] This obligation to indicate a concrete investment intention was waived within the framework of the StÄndG 2015 of 02.11.2015[25] in order to simplify the practical application of § 7g EStG. Nevertheless, the legal standard requires a future acquisition or Production of an economic good. This was for until 31. December 2019 formed IAB within three years after the financial year of formation of the IAB. [26] For IABs formed from the 2020 marketing year onwards, the investment period was extended to four years after the marketing year of formation of the IAB due to the JStG 2020[27]. § 56 Abs. 16 pp. 3, 4 and 5 EStG extends the deadline for IABs formed in 2017 to six years, for IABs formed in 2018 to five years and for IABs formed in 2019 also to four years. [] 28]

For the use of an IAB, the legislator mentions as a further requirement acc. § 7g Abs. 1 S. 2 No. 2 EStG the transmission of the sums of the claimed IAB and those according to § 7g para. 2 to 4 EStG to be added and/or cancelled according to officially prescribed data sets by remote data transmission. Failure to comply with this requirement leads to the loss of entitlement to the tax advantage. [] 29]

In unreasonable cases of hardship, the financial administration may waive electronic transmission on request. This is the case if the electronic transmission is economically and personally unreasonable for the taxable person. [30]

Grds., however, must be transmitted within the framework of the tax returns. If the taxpayer determines his profit according to § 4 Abs. 3 EStG, it transmits its data in the “installation EÜR”. Taxpayers compiling a business asset comparison submit their information as part of the e-balance sheet.[31]

A subsequent assertion or adjustment of an IAB is within the scope of the tax returns without proof grds. possible. However, this is more difficult for IABs formed from the 2021 marketing year onwards, as the legislature limits the formation of an IAB to newly acquired or manufactured assets. If the asset has been acquired or manufactured in the meantime, a subsequent use of an IAB is no longer possible if the tax assessment has already become incontestable. [] 32]

§ 7g EStG is a tax law provision and has no effect on the trade balance result. In the year of use of an IAB, the tax profit is reduced off-balance-sheet in the amount of the IAB formed, up to a maximum of 50% of the expected acquisition or production costs. As a result, the IAB does not affect the size characteristics of the taxpayer, such as the operating assets of an accountant, and the profit determination itself remains unchanged. [] 33]

Grds. is the use of an IAB for assets which, because of their inadequacy acc. § 4 Abs. 1 no. 7 EStG income tax not to be taken into account, not possible.[34]

3.1.2. Loss attributable

pursuant to § 7g para. 3 EStG the law expressly permits that the formation of an IAB may result in a loss or increase. This also increases the potential for loss compensation or return. [] 35

3.2.1. Add-on

If an IAB according to § 7g Abs.1 EStG has been used, the taxpayer acc. § 7g Abs. 1 EStG the possibility to add up to 50% of the actual acquisition or production costs of the beneficiary economic asset in the year of the investment, but at most the sum of the (still) existing IAB, to the profit. The right to vote with the legal word “kann” does not refer in this context to the basic addition of the IAB previously asserted in a profit-reducing manner, but offers the taxpayer a right to vote only in respect of when the addition takes place within the investment period and for which specific asset it is made. If the IAB is to be used, an addition within the deadline must be made in all cases. This is then done, as is the formation of

IAB, off-balance-sheet and results only in a temporary tax relief, since the reduction in profit previously achieved in the marketing year of formation of the IAB is reversed by the addition. [] 36]

Addition is only possible up to 50% of the actual acquisition or production costs. If these are lower than the estimated costs on the basis of which the IAB was formed, no addition may be made up to the IAB in excess of the actual costs. The excess amount may alternatively be used for subsequent acquisition or production costs or other beneficiary assets. Otherwise, reversal is required at the end of the investment period.[37]

An addition in a marketing year before purchase or Manufacture of a beneficiary asset shall not be permitted. § 7g Abs. 1 EStG obviously refers to the actual investment year. If an add-on is omitted despite the acquisition or production of a beneficiary asset, it may be carried out in the case of further investments, provided that they take place within the investment period. [] 38]

Where several IABs have been established in several consecutive marketing years, the taxable person shall not be required to make the addition to the initial IAB. It is also possible to make the additions at the expense of several IABs and thus divide them. In this way, it is possible to control in a targeted manner when which IAB, i.e. shall be reversed. [39]

3.2.2. Profit-reducing reduction of acquisition and production costs

To compensate for the profit-increasing addition according to § 7g para. 1 EStG, waives § 7g para. 3 EStG the possibility of reducing the acquisition or production costs of the beneficiary economic good by reducing profits up to 50% of the actual acquisition or production costs. Assuming an IAB actually used, this reduction has the same effect as unscheduled depreciation.[40] Contrary to the design possibilities described above, the reduction of the acquisition and production costs takes place on an intra-balance sheet basis, since it has an impact on the AfA tax base. It may be made at most in the amount, such as an addition according to § 7g Abs. 2 p. 1 EStG. If it takes place at the same level, this will fully compensate for the impact in the investment year. [41] The tax deferral achieved by the used IAB thus extends to the useful life of the asset. [] 42]

Grds. also has the right to vote for the reduction in favour of the taxpayer. If he makes use of this, the assessment basis for the AfA is reduced in the opposite direction. If the acquisition or production costs fall to at least the minimum. € 800,00 net, is a low value economic asset i.S.d. § 6 Abs. 2 EStG and the remaining amount is bookable as immediate operating expenditure. If, on the other hand, the AfA tax base falls to at least € 1,000.00 net, but max. to € 250.00 net, the entry of the asset into a collective item is in accordance with § 6 para. 2a EStG, which is written off uniformly over a period of use of five years. [43] If, on the other hand, the remaining useful life of the beneficiary asset is less than five years, it is not in the sense of a maximum tax reduction.

It is not possible to allocate the amount of reduction claimed to several assets.[44]

3.3.1. Reversal of an IAB due to lack of investment

§ 7g Abs. 3 EStG regulates the reversal of an IAB if no additional invoice in accordance with § 7g para. 2 p. 1 EStG. Similarly, IABs used must be reversed if they should not have been used, e.g. because an excessive deduction has been claimed or no asset has been purchased within the investment period. or the investment is objectively no longer feasible. [45] IABs are also to be reversed if a change of the profit determination method to § 5a EStG has taken place or the taxpayer sells or ceases his business. [] 46]

Grds. also expressly grants the possibility of voluntary early reversal of an IAB. In order not to lose a tax reduction achieved by the formation of an IAB on the basis of the reversal, the taxable person, provided that there is still an investment intention and this can be credibly demonstrated, can claim a new IAB in the same marketing year of the reversal. [47]

If a triggering event for the reversal occurred, the taxpayer is obliged to notify the tax office, at the latest in the context of the tax return for the corresponding marketing year in which the event occurred.[48] The reversal is then effected by an off-balance-sheet profit increase in the marketing year in which the IAB was originally formed. Corresponding tax or assessment decisions are due by law according to § 7g Abs. 3 S. 2 EStG. [] 49]

3.3.2. Reversal of an IAB due to non-commitment conditions

As already described above, the use of an IAB presupposes that the purchased or manufactured beneficiary economic good from the day after its purchase or production. production is rented or used exclusively or almost exclusively on the holding until the end of the following marketing year. If these usage requirements are not met, grds is. a reversal of the IAB initially formed in the year of its use and related additions and profit-reducing reductions in the acquisition and production costs in the investment year. If there are other assets suitable for the use of an IAB, it is possible to use the IAB for these later. Thus, the originally formed IAB does not necessarily have to be reversed. For IABs set up until the 2015 marketing year, a reversal is nevertheless to be made in all cases, as a concrete investment intention had to be declared until then. If the conditions for use of the specific asset are subsequently not met, the IAB must be reversed. [50]

The special depreciation is described in § 7g para. 5 and 6 EStG. It is not related to the IAB, but is also an independent additional funding instrument and can be used regardless of whether an IAB has been set up or not. Grds. exists according to § 7g Abs. 5 EStG the possibility for usable movable assets of the fixed assets to claim up to a total of 20% of the acquisition or production costs in the acquisition or production year and the four following years as a special depreciation. The ordinary AfA i.S.d. § 7 Abs. 1 or 2 EStG remains unaffected. [] 51]

§ 7g Abs. 6 EStG lays down the conditions for the use of the special depreciation. § 7g Abs. 6 No. 1 EStG limits the beneficiary group of persons to companies whose profits exceed the profit limit of € 200,000,00 acc. § 7g Abs. 1 S. 2 No. 1 EStG in the marketing year preceding the acquisition or manufacture. The beneficiary therefore does not deviate from the category of persons eligible for the use of an IAB. Deviating from the rules of the IAB, however, are the profit determination at the end of the previous marketing year and the irrelevance of the profit determination method. [] 52]

As a second condition, § 7g para. 6 No. 2 EStG the rental of the asset or the exclusively or almost exclusively operational use of the asset in a domestic permanent establishment of the business of the taxable person in the year of its acquisition or manufacture and in the following marketing year. The scope of the beneficiary assets is limited, as in the case of the IAB regulations, to usable movable assets of fixed assets and does not differentiate between new or used assets. [] 53

The five-year period is not linked to the aforementioned usage requirements. From the third year onwards, a private use of more than 10% of the beneficiary economic asset is therefore possible without this having a detrimental effect on the use of the special depreciation. [] 54]

The special depreciation is made on an intra-balance sheet basis. Are the requirements according to § 7g Abs. 6 EStG, the taxpayer can within five years of purchase or manufacture up to max. 20% of the acquisition or production costs of the beneficiary asset as a special depreciation according to free design. It is carried out in addition to the linear or degressive AfA, and has no effect on its tax base. [] 55

Grds. the degressive AfA for movable assets of fixed assets was reintroduced under the second Corona Tax Assistance Act of 29 June 2020[56] for the years 2020 and 2021. Due to the fourth Corona Tax Assistance Act of 19 June 2022[57], the period of application was extended to 2022. [] 58]

Serve as a basis for the assessment of the special depreciation in accordance with § 7g para. 5 EStG the acquisition or production costs of the respective economic asset, the basis of assessment for the ordinary AfA not being decisive for this. This can be done grds. of a smaller amount. [] 59]

If an IAB was previously used for the beneficiary economic good and was carried out in accordance with § 7g para. 3 EStG the profit-reducing reduction of the acquisition or production costs, but also reduces the tax base for the special depreciation at a corresponding amount. An absolute maximum amount for special write-offs, such as there is for IAB, does not provide for the law. [60]

If there is a subsequent change in profit i.S.d. § 7g para. 1 S. 2 No. 1 EStG and this leads to an overrun of the € 200,000.00 limit, the claimed special write-off is retroactively refused. § 7g para. 6 no. 2 2. half sentence EStG reference to the provisions of § 7g para. 4 EStG, according to which, in the event of a reversal, all profit-relevant consequences of the special write-off must also be reversed. [] 61]

§ 7g EStG offers beneficiary taxpayers ample room for manoeuvre with regard to their tax liability and is a suitable means of facilitating investment by small and medium-sized enterprises. Especially in the year of formation of an IAB, an enormous tax reduction is possible, since the taxpayer has the opportunity to influence the amount of the tax reduction due to his right to choose between the formation of an IAB of 1 to 50% of the expected acquisition or production costs of the beneficiary asset. The elimination of the obligation to declare the investment intention also significantly facilitates the practical application. Due to the legally compliant possibility of causing a loss by an IAB or This increase also increases the liquidity, since a loss transfer into the previous year is possible, which allows the taxpayer to be refunded any taxes already paid.

In the year of the formation of the IAB, a tax deferral and thus liquidity security is achieved for the time being. Due to the compelling profit-increasing addition, these advantages were gross. again, but this compensates for the possible profit-reducing reduction of the acquisition or production costs. Although this reduces the AfA tax base of the respective asset for the future marketing years, which triggers a lower AfA and thus lower operating expenses, this disadvantage is partly compensated by the possible special depreciation.

Nevertheless, § 7g EStG offers a good opportunity to achieve liquidity guarantees and tax deferrals and, as a result, to remain more competitive and to become stronger in terms of investment and innovation.

[1] BGBl. I 1983, 1583, 1586.

[2] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 1f.

[3] BGBl. I 2007, 1912, 1914.

[4] Frotscher/Geurts – Kratzsch, EStG § 7g Rz. 1.

[5] BGBl. I 2015, 1834, 1835.

[6] Leingärtner/Zaisch – Wendt, Chapter 30. Deductions and write-offs, paragraph 70.

[7] BGBl. I 2020, 3097.

[8] Güldenstern, STFAN 4/2022, 14.

[9] Frotscher/Geurts – Kratzsch, EStG § 7g Rz. 2.

[10] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 10f.

[11] Geiermann, AfA-Lexikon, ABC der depreciations Investment deduction amount according to § 7g EStG, paragraph 12.

[12] KKB – Egner/Stößel, EStG § 7g Rz. 23.

[13] Geiermann, AfA-Lexikon, ABC of the write-downs “investment deduction amount according to § 7g EStG”, paragraph 18.

[14] BGBl. I 2020, 3097.

[15] Geiermann, AfA-Lexikon, ABC of the write-downs “investment deduction amount according to § 7g EStG”, paragraph 26.

[16] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 26f.

[17] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 35.

[18] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 39.

[19] BGBl. I 2020, 3097.

[20] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 23f.

[21] Littmann/Bitz/Pust – Handzik, EStG § 7g paragraph 69f.

[22] Geiermann, AfA-Lexikon, ABC of the write-offs ‘investment deduction amount according to § 7g EStG’, paragraph 65f.

[23] KKB – Egner/Stößel, EStG § 7g paragraph 77.

[24] Frotscher/Geurts – Kratzsch, EStG § 7g Rz. 23.

[25] BGBl. I 2015, 1834, 1835.

[26] KKB – Egner/Stößel, EStG § 7g Rz 45f.

[27] BGBl. I 2020, 3097.

[28] Meinert/Heeke – NWB No 29 of 23.07.2021, 2139, 2145.

[29] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 60.

[30] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 63.

[31] KKB – Egner v Stoessel, EStG § 7g paragraph 66.

[32] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 34.

[33] Frotscher/Geurts – Kratzsch, EStG § 7g Rz. 59.

[34] KKB – Egner/Stößel, EStG § 7g paragraph 78.

[35] Schmidt – Kulosa, EStG § 7g paragraph 50.

[36] Egner/Stößel, NWB Grundlagen v. 06.02.2022, paragraph 41 et seq.; Geiermann, AfA-Lexikon, ABC of the write-downs ‘Investment deduction amount according to § 7g EStG’, paragraph 73.

[37] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 74.

[38] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 75f.

[39] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 80.

[40] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 81.

[41] Brandis v Heuermann – Brandis, EStG § 7g paragraph 65.

[42] Geiermann, AfA-Lexikon, ABC of the write-offs ‘investment deduction amount according to § 7g EStG’, paragraph 84.

[43] Geiermann, AfA-Lexikon, ABC of the write-offs ‘investment deduction amount according to § 7g EStG’, paragraph 82.

[44] Geiermann, AfA-Lexikon, ABC of the depreciation ‘investment deduction amount according to § 7g EStG’, paragraph 83.

[45] KKB – Egner/Stößel, EStG § 7g Rz. 106.

[46] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 50.

[47] KKB – Egner/Stößel, EStG § 7g Rz. 107.

[48] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 49.

[49] Geiermann, AfA-Lexikon, ABC of the write-offs ‘investment deduction amount according to § 7g EStG’, paragraph 90f.

[50] Schmidt – Kulosa, EStG § 7g paragraph 67.

[51] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 58.

[52] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 59f.

[53] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 62.

[54] KKB – Egner/Stößel, EStG § 7g Rz. 158.

[55] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 64.

[56] BGBl. I 2020, 1512.

[57] BGBl. I 2022, 911, 912.

[58] Gulenstern, STFAN 4/2022, 14, 17.

[59] Frotscher/Geurts – Kratzsch, EStG § 7g Rz 91.

[60] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 64.

[61] Egner/Stößel, NWB Grundlagen v 06.02.2022, paragraph 67.