With regard to the 2013 Annual Tax Act, it has been recommended to the German Federal Council by its own Committees to convene the Mediation Committee, a joint legislative body comprising equal numbers of members from the German Parliament and the German Federal Council.

After several amendments suggested by the German Federal Council did not make it into the legislative draft of the 2013 Annual Tax Act, the Federal Council will again debate the draft on November 23, 2012. The Federal Council's position statement will be based on recommendations by its Committees issued on November 13, 2012. The Committees recommend convening the Mediation Committee, inter alia, to introduce tax liability for income from hybrid financial instruments, tax liability for dividends and capital gains on profit sharing of widely held stock (<10%) as well as rules for the avoidance of tax structuring models using so-called real estate transfer tax (RETT) blocker partnerships.