Germany - The German Silent Partnership
- M. Lipp
- European Taxation, 2015 (Volume 55), No 7
- 10 June 2015
The author, in this note, provides a general overview of the taxation of silent partnerships in Germany. As an example of a hybrid financial instrument, silent partnerships reflect the traditional tax distinction between debt and equity. Their use can lead to double taxation or double non-taxation in a cross-border context and it is, therefore, necessary to examine them critically.