Motion on the Taxation of Very Large Net Assets
The parliamentary group Bündnis 90/Die Grünen submitted a motion to the Bundestag (German Federal Parliament) for the introduction of an additional tax on very large assets. The motion is entitled “500 Million Tax – Fairer Participation of Extreme Wealth” and was introduced as Bundestagsdrucksache 21/8267 (Bundestag printed paper 21/8267) on 29 September 2026 in the 21st legislative term.
According to the motion, individuals with net assets of more than EUR 500 million would be subject to a new tax. A tax-free allowance of EUR 500 million is envisaged. The levy would only apply above this threshold.
In addition to the parliamentary group, the applicants include Karoline Otte, Katharina Beck, Dr. Sebastian Schäfer, Dr. Andreas Audretsch, Dr. Moritz Heuberger, Max Lucks, Sascha Müller, Stefan Schmidt, Felix Banaszak, Dr. Franziska Brantner, Timon Dzienus, Lisa Paus, Dr. Paula Piechotta, Jamila Schäfer and Johannes Wagner.
Structure of the Proposed 500 Million Tax
Linear Progressive Tax Rate
The motion provides for linear progressive taxation. This would apply to net assets above the tax-free allowance of EUR 500 million and would begin with a minimum marginal tax rate of two percent.
Under the concept, the following brackets would apply:
- from EUR 500 million in net assets: minimum marginal tax rate of two percent,
- from EUR one billion in net assets: increase to three percent,
- from EUR ten billion in net assets: tax rate of four percent.
Income tax already paid would be credited against the 500 million tax. The parliamentary group expects the new tax to generate additional annual revenue of more than EUR 20 billion.
Distribution of the Expected Revenue
According to the plans, the expected additional revenue of more than EUR 20 billion per year would largely, but not entirely, benefit the Länder (German federal states). This is justified on the basis that, unlike a classic wealth tax, taxes already paid would be credited.
According to the parliamentary group, only a few hundred of the approximately 84 million people in Germany would be affected by the tax. This would correspond to the wealthiest 0.0007 percent of the population.
Reasons for the Motion
Criticism of Wealth Concentration
In the explanatory statement to the motion, the parliamentary group Bündnis 90/Die Grünen states that people with extremely large assets are “structurally and to a high degree” privileged within the tax system. In the view of the parliamentary group, the German tax system favours and reinforces the concentration of wealth.
By way of justification, the motion refers to the different tax burden on earned income and capital income. Earned income may be subject to taxes and contributions of up to 48 percent. By contrast, all capital income is taxed at a maximum of approximately 26 percent.
Holding Structures and Capital Income
The motion also addresses the taxation of capital income through holding structures. According to the parliamentary group, billionaires can accumulate capital income through such structures almost tax-free.
If distributed capital gains are retained in holding structures and not paid out to private accounts, the tax on these distributions is only 1.5 percent according to the explanatory statement to the motion. The parliamentary group contrasts this with taxation of approximately 26 percent for natural persons.
In an accompanying explanatory paper by the parliamentary group, it was cited as an example that currently 300 apartments could be inherited tax-free, while tax would be incurred on three apartments.
Fiscal Policy Context of the Initiative
Stated Financing Need
To justify the need for regulation, the motion also refers to public financing issues. According to this, the budgets of cities and municipalities lack more than EUR 30 billion annually. In addition, the Bundesregierung (Federal Government) states that there is a financing gap of more than EUR 100 billion for the years 2028 to 2030.
The parliamentary group therefore places the proposal in the context of what it sees as a need for additional government revenue. The concept was publicly presented in Berlin on 29 September 2026 by the parliamentary group’s specialist policymakers.
Karoline Otte, one of the co-authors, is a member of the Bundestag’s Finance Committee for Bündnis 90/Die Grünen. According to the available information, the proposal was developed internally within the party over several months; the “Zeit” was the first to report on it.
Reference to Further Tax Policy Bills and Motions
The initiative coincided with further tax policy deliberations in the Bundestag. On 8 October 2026, government proposals on income tax reform under printed paper 21/8235 and on the Annual Tax Act under printed paper 21/8283 were debated at first reading. Among other things, these proposals provided for a higher tax rate for high earners.
On the same sitting day, a further motion by the parliamentary group Bündnis 90/Die Grünen entitled “Actually Relieve Low and Middle Incomes and Strengthen the Building of Reserves and Assets” under printed paper 21/8379 was also considered.
Study Data on Very Large Assets
In its motion, the parliamentary group Bündnis 90/Die Grünen refers to studies according to which billionaire wealth increased by an average of 121 percent between 2015 and 2024. According to the presentation, this corresponds to an annual return of more than ten percent.
Against this background, the members of parliament argue that the concept does not amount to taxation of capital substance. In support of this, they rely on what they consider to be very high returns on extremely large assets and on the intended crediting of income tax already paid. The tax rates envisaged in the concept are significantly below the higher return expected by the parliamentary group.
Parliamentary Consideration on 8 October 2026
On Thursday, 8 October 2026, the Bundestag rejected, in a roll-call vote, four motions and three bills submitted by the parliamentary group Bündnis 90/Die Grünen on tax policy. A motion by the parliamentary group Die Linke also failed to secure a majority by show of hands.
In one of the roll-call votes that day, 578 votes were cast. Of these, 445 votes were against, 132 were in favour and one vote was an abstention.
For 8 October 2026, the Greens had deliberately scheduled seven roll-call votes on tax issues. According to the available information, the aim was to prompt members of the Union and SPD to take an open position. Katharina Beck of Bündnis 90/Die Grünen described the proposals in the debate as “seven votes on seven justice gaps”.
Significance for Tax Law and Wealth Structuring
The motion concerns central issues in the taxation of large assets, the distinction between income taxation and wealth taxation, and the tax treatment of capital income and participation structures. For companies, investors and high-net-worth individuals, such tax policy initiatives may already be of considerable importance at the stage of parliamentary discussion, even without resulting in a specific change in the law.
MTR Legal Rechtsanwälte advises clients on tax law issues with an international dimension as well as on the classification of national tax regulations. Anyone wishing to have the legal implications of tax policy developments for existing asset, participation or corporate structures reviewed can find further information at Legal advice in tax law.
