Short answer: The location difference becomes smaller, but does not automatically disappear versus Berlin. Schönefeld publishes 240% for 2026 and Berlin 410%. From 2027, section 36(5b) GewStG first applies a statutory minimum of 280%. Schönefeld's adopted rate and any Berlin change must be checked when a decision is made.
What changed in law?
Section 16(4) sentence 2 GewStG now sets a 280% minimum. Section 36(5b) states that it first applies to the 2027 tax period. The Federal Ministry of Finance explicitly links the increase to countering relocations that exist only on paper.
The numbers: 2026 versus a 2027 planning scenario
Simplified example for a corporation with €250,000 taxable business income and the 3.5% assessment rate. Additions, deductions, losses carried forward and other fixed places are excluded.
| Location / scenario | Multiplier | Calculated municipal business tax | Difference vs Berlin |
|---|---|---|---|
| Berlin | 410 % | 35.875 € | - |
| Schönefeld 2026 | 240 % | 21.000 € | 14.875 € |
| Schönefeld 2027* | 280 %* | 24.500 €* | 11.375 €* |
* Planning scenario assuming Schönefeld adopts 280% and Berlin remains at 410%. This is not a forecast or guarantee.
Why genuine substance matters even more now
The reform rationale targets paper-only locations. The practical message is clear: a commercial-register entry alone does not decide the tax location. Section 4 GewStG refers to a fixed place of business; section 10 AO defines management as the centre of top-level management, and section 12 AO defines a fixed business facility serving the company.
What prospects should establish before a move
- Where are material management decisions genuinely made?
- Which Schönefeld premises are actually used, and to what extent?
- Are there staff, warehouses, home offices or other fixed places in other municipalities?
- Do the expected difference, location costs and transition effort still make commercial sense at a minimum of 280%?
- Are corporate, registry, business-registration and tax steps aligned with professional advisers?
Who may still find Schönefeld suitable?
A BER-area base may remain relevant where it fits the real operating model, for example, digitally run companies, consultancies, agencies, e-commerce or trading businesses managed in the Berlin-Brandenburg region. The case should rest on genuine use, accessibility and a coherent setup, never a mailbox alone.
