Political agreement amends tax treatment of long-term price hedging contracts
Under the new political agreement, the taxation will shift from a mark-to-market (inventory) principle – which requires companies to recognise value fluctuations for tax purposes irrespective of actual cash flow – to taxation based solely on realised payments under hedging contracts such as PPAs and CfDs.
The purpose of the amendment is to mitigate liquidity challenges by better aligning the tax framework with commercial reality and strengthening the conditions for long-term investments supporting the green transition. Since the change only alters the timing of taxation, the amendment is not expected to affect the overall tax burden over time or have any fiscal impact.
The agreed changes apply to contracts with a duration of three years or more entered into from 1 January 2026 onwards. The legislative amendment will therefore apply to CfD agreements concluded as part of the upcoming tenders for three offshore wind farms, two of which have bid deadlines in spring 2026 and the third in autumn 2028.