E-mobility: 75 percent special depreciation for open leasing contracts

Leasing is excluded from the new special depreciation allowance for electric company cars. The situation is different for "open" leasing contracts.

The German government's investment boost includes, among other things, a new depreciation method for electric company cars purchased after June 30, 2025, and before January 1, 2028. In the first year, companies can deduct 75 percent of the purchase price for tax purposes , and in the following five years, they can deduct 10 percent, 5 percent, another 5 percent, 3 percent, and 2 percent respectively.

However, this regulation only applies to purchased vehicles. Therefore, companies that lease their fleets using mileage/term contracts are left out. This is because leasing constitutes a paid transfer to a third party; the vehicles are considered current assets, not fixed assets. 

The German Automotive Trust (DAT) therefore described the funding instrument as one that misses the mark in practice. "Those who lease cannot depreciate. This means that the tax relief does not benefit the company using the vehicle – but rather the leasing company. Thus, the measure misses the mark for most corporate clients," said DAT Managing Director Jens Nietzschmann.

Das Modell

However, this does not apply to purchase-like "open" leasing contracts (see Federal Ministry of Finance letter of April 19, 1971 – IV B/2 – S 2170 – 31/71). These meet the requirements for depreciation because the vehicles become part of the company's assets.

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Lessees also pay fixed installments. However, these do not cover the refinancing costs and profit margin of the leasing company, but rather serve to finance the individual vehicle. "The lessee alone determines the lease term. They can terminate the contract as early as the third month by paying off the outstanding balance and then freely dispose of their vehicle," says Henning Schick , Sales Director at the German branch of the US-based Holman Group , which has been offering the open-ended lease agreement as its main product for commercial fleets in Germany since 2015.

Large liquidity effect

For example, a medium-sized company with 50 company cars currently calculates its costs using traditional three-year lease agreements. With a Skoda Enyaq (list price €25.196/lease payment according to current price guidelines €375), switching to open-ended leases would allow the company to claim €944.873 in tax deductions in the first year alone.

Schick: "Open-ended leasing contracts combine the advantage of predictable monthly payments with full tax benefits. This is particularly interesting for medium-sized businesses that want to limit their financing costs while simultaneously optimizing their tax burden."

High flexibility

Furthermore, the company can replace the vehicles after just one year, thereby adapting its fleet to operational requirements or technological developments – such as increased range or new charging options. This reduces the risk of being stuck with outdated technology. The combination of immediate tax benefits and operational flexibility makes electrification economically viable.

The special depreciation allowance is not linked to a separate application process but is claimed as part of the regular tax return. At the same time, the tax price ceiling for purely electric company cars that benefit from the favorable 0,25 percent tax rate was raised from €70.000 to €100.000 on July 1, 2025. This means that even higher-priced vehicles can continue to benefit from tax advantages. If this limit is exceeded, the 0,5 percent rule applies again.

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