What does the BMF Schreiben Forschungszulage say – and what applies today?
Summary
The BMF letter dated 07/02/2023 is the official administrative guidance on the Forschungszulage (public funding) for research and development. It explains how tax offices interpret the Forschungszulagengesetz (FZulG): Who is eligible to apply? What counts as R&D? Which costs are eligible? How does the process work? This letter is formally still the key basis – but the specific figures have changed significantly since 2024.
Formally, this letter is still the key basis. However, the legal situation has changed several times since 2024—through the Wachstumschancengesetz and the Investitionssofortprogramm. A draft for a new BMF letter has been available since October 2025; the final version is still pending.
In practice, this means: the 2023 letter remains a useful reference, but the specific figures (assessment base, funding rates, eligible costs) have changed significantly.
What is the BMF Schreiben Forschungszulage?
The BMF letter is an administrative instruction issued by the German Federal Ministry of Finance. It describes how the tax administration applies the Forschungszulagengesetz in practice—essentially an instruction manual for tax offices and, indirectly, for all companies that want to apply for the Forschungszulage (public funding).
The letter dated 07/02/2023 replaces the previous one from 11/11/2021 and covers four areas:
- Substantive legal issues: Who may apply? What is an eligible R&D project? Which costs count?
- Procedure: BSFZ certificate, application to the tax office, deadlines, assessment
- Income tax treatment: How is the allowance shown in the accounts?
- State-aid law: GBER (AGVO), de minimis, combining with other funding
Official source: BMF letter dated 07/02/2023 (PDF)
Why the 2023 letter still matters – but is no longer sufficient
The BMF letter remains the best reference for procedural questions, R&D classification, and documentation requirements. Many rejections do not happen because of the costs, but because the project scope or the evidence is not correct—this is exactly why the letter is still the most important practical basis.
What has changed: the specific funding parameters (assessment base, rates, eligible cost categories) have been increased since 2024 through two major legal amendments. The 2023 letter does not reflect these changes. A draft of a new BMF letter was published in October 2025 (comment deadline: 11/11/2025); the final version is currently still pending.
Timeline: What changed when?
More details in the overview of changes in 2024 and 2026.
01/01/2020 – Introduction of the Forschungszulage
Assessment base: €2 million, funding rate: 25%, contract R&D: 60%
07/01/2020 – Second Corona Tax Relief Act
Assessment base doubled to €4 million
02/07/2023 – Current BMF letter
Replaces the 2021 letter; clarifications on documentation, associated companies, contract R&D
03/27/2024 – Wachstumschancengesetz
Assessment base to €10 million, contract R&D to 70%, SME bonus (35% instead of 25%), own work to €70/h, depreciation on R&D assets eligible
October 2025 – Draft new BMF letter
Alignment with legal changes; comment deadline 11/11/2025; final version pending
01/01/2026 – Investitionssofortprogramm
Assessment base to €12 million, 20% overhead lump sum (for projects starting in 2026), own work to €100/h, maximum funding: up to €3 million (large enterprises) or €4.2 million (SMEs)
Official links
- BMF letter dated 07/02/2023 (PDF)
- German Federal Ministry of Finance – Forschungszulage
- BSFZ: Certification body Forschungszulage
- Forschungszulagengesetz (FZulG)