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Iraq Company from Germany 2026: the Siemens Pipeline

Siemens Energy signed for 14 GW of Iraqi generation capacity, with KfW financing behind parts of it. What that pipeline means for a German supplier's entity.

Charles Martin
Charles MartinFounder, CorpSec
Updated September 202611 min read
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Germany's presence in Iraq is written almost entirely in electricity, and it is written at scale.

Siemens Energy has signed with Iraq's Ministry of Electricity to develop 14 GW of new gas-fired generation capacity, built as combined-cycle plants running primarily on locally sourced gas, including gas currently flared during oil production. Alongside it sit the rehabilitation of the 340 MW Dibis plant, work at Al-Musayyib covering 750 MW of existing units plus 150 MW of addition, five high-voltage substations across Baghdad, Diyala, Najaf, Karbala and Basra, and a USD 1.3 billion contract with Orascom Construction to rebuild the Baiji power plant complex.

For a German Mittelstand supplier, that is the corridor. Not operating plants, but selling into the programme that builds them.

Key facts for German founders

QuestionAnswer
Can a German company own 100% of an Iraqi company?Not a federal LLC. Capped at 49% since 2019
Full ownership anywhere in Iraq?Yes, in the Kurdistan Region
Iraqi corporate tax15%, or 35% in oil and gas and related industries
Tax on dividends leaving IraqNone
German CFC exposureOn the line. AStG threshold is 15%, Iraq taxes at 15%
What flips the CFC answerAn investment licence, which drops the effective rate to zero

Germany cut the AStG threshold from 25% to 15% for 2024. Iraq taxes at 15%. That is not comfort, it is a zero margin, and the investment licence erases it.

The pipeline, and where a supplier fits

ProgrammeScale
Combined-cycle generation with the Ministry of Electricity14 GW of new capacity
Baiji power plant complex, with Orascom ConstructionUSD 1.3 billion
Al-Musayyib thermal plant750 MW rehabilitated, 150 MW added
Dibis gas-fired plant340 MW renovation
High-voltage substationsFive, across Baghdad, Diyala, Najaf, Karbala and Basra

Two features of this pipeline matter for a supplier.

It runs on domestic gas, including flared gas. That ties the electricity programme to the gas capture work happening across the oil fields, which is why power and upstream procurement overlap and why the tax perimeter question below is live.

German state financing appears in it. KfW, the German development bank, has been reported as financing project work in this space. That is worth pursuing project by project rather than assuming, and it is a channel most competitors from other origins do not have.

Can a German resident legally own an Iraqi company?

Yes, up to 49% of a federal LLC, since Law No. 17 of 2019 requires Iraqi shareholders to hold at least 51%. Full ownership is available in the Kurdistan Region following its January 2022 amendments, and is understood to be available through an investment licence, with that point not fully settled.

Every foreign shareholder, individual or corporate, clears a Ministry of Interior security check before being recorded, which is why federal registration is quoted as six to twelve weeks.

The German analysis, which is unusually simple

Three German tests, and the first one is closer than it looksThe AStG low-tax threshold fell from 25% to 15% for financial years from 2024. Iraq at 15% clears it by exactly nothing, because the test is less than 15% rather than 15% or below.
  1. 1Hinzurechnungsbesteuerung: on the lineThe threshold is a burden of less than 15%. Iraq is taxed at 15%, so a fully taxed Iraqi company sits outside by zero margin, and the 35% oil and gas rate is clearly outside.
  2. 2The investment licence reverses itA project licensed by the National Investment Commission is exempt for up to ten years. An effective rate of zero is below 15%, which places the entity inside the regime the statutory rate kept it out of.
  3. 3Geschäftsleitung: still the issueUnder §10 Abgabenordnung a company managed in fact from Germany can be treated as German resident whatever the register says. That test does not care about the Iraqi rate at all.
Source: §8(5) Außensteuergesetz as amended for 2024 and §10 Abgabenordnung, September 2026

The consequence most German guidance misses. The AStG threshold was lowered from 25% to 15% by the minimum tax implementing legislation, for financial years beginning in 2024. That change made Iraq borderline rather than comfortable: 15% is not above 15%, it is on it, and it escapes only because the statute says less than 15%.

Which means the incentive and the exposure point the same way:

  • A fully taxed Iraqi company at 15% sits outside the regime, with no margin at all.
  • A project with an investment licence is exempt for up to ten years, so its effective rate is zero and it sits inside.
  • Any Iraqi mechanism that reduces the effective burden below 15% has the same effect, whatever its label.

Take the German advice on the licence before applying for it, not after. Detail on the licence in Iraq corporate tax.

The other practical consequence for a German group is that the Iraqi entity should be genuinely run from Iraq: real premises, decisions taken and minuted there, and a manager who manages. That is the same discipline required in every jurisdiction, with the difference that here it is the only German question rather than one of two.

Separately, export control and end-use screening applies to power and industrial equipment sold into the region, and it belongs at the contracting stage rather than at shipping.

The Iraqi rate question

Iraq taxes at 15%, but 35% applies to income from contracts with foreign oil companies, their branches and offices, and subcontractors working in oil and gas production and related industries.

For a power supplier the boundary is genuinely live, because the generation programme runs on gas captured at oil fields. Establish which side your contract sits on before pricing:

  • Generation and grid work outside the production perimeter is likely at 15%, and should be confirmed.
  • Work performed for or alongside upstream operations may pull into 35%, since the scope reaches subcontractors and related industries.
  • Non-upstream industries contracted with oil and gas companies face 15% plus a retention of 3.3% or 7% on payments.

How the tax is actually computed, using deemed profit percentages by contract type rather than your real margin, is in Iraq corporate tax.

The Iraqi side, in short

  1. Establish whether you are trading with Iraq or in it, which decides whether an entity is needed at all.
  2. Choose the route: branch against a qualifying contract, LLC at 49%, or a Kurdistan entity.
  3. Clear the Ministry of Interior check for every foreign shareholder.
  4. Deposit IQD 1,000,000 in an Iraqi bank, verified at registration.
  5. Appoint a managing director and a deputy, with a resident manager.
  6. Obtain the tax identification number early, because it gates the official currency channel.

Full sequence in how to register a company in Iraq.

When Iraq makes sense from Germany, and when it does not

SituationVerdict
Supplying equipment into the generation or grid programmeStrong, this is the corridor
Long-running commissioning or service obligation on siteStrong, and it needs an entity
A project with a KfW financing routeStrong, pursue it project by project
One-off equipment supply, installed by othersPossibly trading with Iraq, no entity needed
Reducing German taxNo. Iraq is not a low-tax jurisdiction
Running the Iraqi entity from GermanyNo. §10 AO does not care what the register says
The German corridor is electricity, and it is largeA Mittelstand supplier is not building plants. It is selling into the programme that builds them, and the scale is what makes that viable.
14 GWof new combined-cycle generation capacity contracted with the Ministry of Electricity
USD 1.3bnthe Baiji power plant complex rebuild with Orascom Construction
5high-voltage substations across Baghdad, Diyala, Najaf, Karbala and Basra
Source: Siemens Energy and Iraqi Ministry of Electricity announcements

Common mistakes from Germany

  • Worrying about the Außensteuergesetz. It is the wrong concern here, and it distracts from the management question that does apply.
  • Running the entity from Germany, which puts the Geschäftsleitung test in play regardless of the Iraqi rate.
  • Assuming 15% because you sell power equipment, when the generation programme runs on gas captured at oil fields and the 35% scope reaches subcontractors in related industries.
  • Assuming KfW financing applies across a programme. It has been reported for specific projects and should be confirmed one by one.
  • Treating export control as a shipping step rather than a contracting condition.
  • Leaving the Iraqi tax identification number late, which blocks the official dollar rate.

What a German supplier should settle before quoting:

  • Which side of the 35% perimeter the contract sits on, since power and upstream procurement overlap in this programme.
  • Whether a KfW financing route exists for that project, pursued project by project rather than assumed.
  • Where the Iraqi entity is actually managed, because §10 AO looks at the facts rather than the register.

The bottom line, and how CorpSec helps

Germany's Iraq story is electricity: 14 GW of new capacity signed, a USD 1.3 billion reconstruction at Baiji, plant rehabilitations and substations, running on domestic and previously flared gas. A German supplier's opportunity is inside that procurement, not beside it.

The German tax analysis has two moving parts rather than one. Iraq at the statutory rate sits outside the CFC regime by exactly nothing, and an investment licence moves it inside. Alongside that sits the ordinary discipline about where the company is run and about which side of the 35% perimeter your contract falls. Settle the second with an Iraqi adviser and the first with your Steuerberater, then pick the entity.

CorpSec structures Iraqi entries end to end, in federal Iraq and the Kurdistan Region, alongside your German advisers.

Frequently asked questions

Can a German company own an Iraqi company?

Up to 49% of a federal LLC, since Law No. 17 of 2019 requires Iraqi shareholders to hold at least 51%. Full ownership is available in the Kurdistan Region and is understood to be available through an investment licence.

Does the Außensteuergesetz apply to an Iraqi subsidiary?

Not automatically, but the margin is zero. The threshold is a burden of less than 15% and Iraq's statutory rate is exactly 15%, rising to 35% in oil and gas, so a fully taxed Iraqi operating company is not the profile the regime targets. The place of management test under §10 Abgabenordnung still applies.

What is Siemens Energy building in Iraq?

An agreement with the Ministry of Electricity to develop 14 GW of new gas-fired combined-cycle capacity, alongside rehabilitation of the Dibis and Al-Musayyib plants, five high-voltage substations, and a USD 1.3 billion reconstruction of the Baiji complex with Orascom Construction.

Is KfW financing available?

KfW has been reported as financing project work in this space. Treat it as a channel to pursue project by project rather than as a facility that applies across the programme.

Will I pay 15% or 35%?

The 35% rate reaches foreign oil companies, their branches and offices, and subcontractors in oil and gas production and related industries. Because the generation programme runs on gas captured at oil fields, a power supplier should establish which side of the line its contract sits on.

Do I need an Iraqi entity to supply equipment?

Not necessarily. Supplying from Germany with the work performed abroad may be trading with Iraq rather than in it. Commissioning, supervision or a service obligation on site points the other way.

How long does registration take?

Six to twelve weeks in federal Iraq because of the Ministry of Interior clearance every foreign shareholder must pass, and two to four weeks in the Kurdistan Region.

Is there tax on repatriating profits to Germany?

Iraq does not tax the dividend again in the shareholder's hands. The practical constraint is access to the official foreign exchange channel, which requires an Iraqi tax identification number.

What about export controls?

Screening applies to power and industrial equipment sold into the region, and it belongs at the contracting stage. Discovering a licensing requirement after signing is expensive and avoidable.

Should I consider the Kurdistan Region?

Only if the work is there. It permits full foreign ownership and registers in two to four weeks, but the generation programme described here is federal.

Sources

The Siemens Energy agreements with Iraq's Ministry of Electricity, including the 14 GW combined-cycle programme, the Dibis and Al-Musayyib rehabilitation works, the Baiji power plant reconstruction with Orascom Construction and the high-voltage substations, come from press reporting across 2025 and 2026 and describe signed agreements and announced programmes rather than completed works. KfW involvement is reported for specific projects and should be confirmed project by project rather than assumed across the programme. The 51% Iraqi ownership requirement follows Law No. 17 of 2019. The low-tax threshold in section 8(5) of the Aussensteuergesetz was reduced from 25% to 15% with effect from the 2024 assessment period, so an Iraqi entity taxed at the statutory 15% falls outside the regime only because the test is a burden of less than 15%, with no margin; an investment licence that removes the charge places it inside. The place of management test under §10 Abgabenordnung applies regardless of the rate. Export control screening applies to power and industrial equipment sold into the region. This is not legal or tax advice.

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