Recent challenges for inbound PE structures in Germany

June 30 2012

Stephan Eilers and Alexander Schwahn of Freshfields Bruckhaus Deringer provide a brief overview of a classic structure for a private equity investment in Germany, and they critically analyse the efforts of both the tax authorities and the legislature to place restrictions on debt push-down structures.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: Tax need not be just about revenue for governments (yes, seriously!)

In looking at the impact of taxation, money won't always be all there is to it

Sam Sholli, January 09 2026

Direct Tax

Australia’s TPB welcomes Andrew Orme as new secretary

Australia’s Tax Practitioners Board is set to kick off 2026 with a new secretary to head the administrative side of its regulatory activities.

Tom Ravlic, January 09 2026

Direct Tax

This week in tax: Ireland records €8.6 billion rise in tax receipts

Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation

Sam Sholli, January 09 2026

Transfer Pricing

IKEA announces intention to dispute A$171m ATO tax claim

The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes

Sam Sholli, January 07 2026

Indirect Tax

This month in indirect tax: UK supermarket loses VAT court battle

Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs

Sam Sholli, January 07 2026

Direct Tax

Landmark pillar two side-by-side agreement reached

The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two

Tom Baker, January 05 2026

Awards

ITR World Tax 2026 website - 1200x627.png

ITR World Tax 2027 and ITR Tax Awards 2026 opens for submissions

ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally

John Harrison, January 05 2026

Direct Tax

EU pillar two directive may violate freedom of establishment: academic

Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued

Sam Sholli, January 05 2026

Direct Tax

Brazilian advisers warn of disputes over crypto transaction tax proposals

Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR

Sam Sholli, December 23 2025

Direct Tax

A taxing week: Trump’s pillar two deal won’t save the project

The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two

Sam Sholli, December 22 2025