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

Feature Sponsored ITR Magazine July / August 2012

more across site & shared bottom lb ros

More from across our site

Direct Tax

r and d - acronym from wooden blocks with letters. background hands on a laptop with blur. business concept.

Capital v revenue in R&D – isolated concerns or a future battleground? Part one

In the first of a two-part series on capital v revenue in R&D, Jayne Stokes explores these key concepts and where UK companies need to tread carefully

Jayne Stokes, June 09 2026

Direct Tax

A&M.jpg

A&M Tax continues Europe push with Sweden launch

Magnus Pantzar is set to join as managing director after spending nearly a decade as EQT’s global head of tax

Sam Sholli, June 08 2026

Direct Tax

Williams-Matt .jpg

Pillar two criticism fair despite filing penalty waiver: BDO tax leader

The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals

Sam Sholli, June 08 2026

Sponsored

Sameer Nurmohamed new.jpg

Sponsored by Deloitte

Deloitte – Canada tax controversy interview

Sameer Nurmohamed, partner, Deloitte Legal Canada

June 05 2026

Sponsored

George Ankomah.jpg

Sponsored by Deloitte

Deloitte – Africa tax controversy interview

George Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)

June 05 2026

Direct Tax

A taxing week: Ryan’s Svalner Atlas deal shows that size does matter

The recent spree of firm mergers and acquisitions proves that geographic scale is the name of the game

Tom Baker, June 05 2026

Direct Tax

Global digital

This week in tax: Taxand expands UK network with Unity Advisory

The big four spin-off firm becomes Taxand’s second UK member; in other news, Haynes Boone launched a UK tax practice

Tom Baker, June 05 2026

Sponsored

Hourglass on financial graphs and reports

Sponsored by Deloitte Luxembourg

Tax uncertainties arising from timing differences: key concepts and practical implications

Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes

Jean-Michel Henry, June 04 2026

Transfer Pricing

Stephanie photo.jpg

‘TP is a team sport’: NRF’s new hire on practice-building

Stephanie Pantelidaki’s economic expertise will give Norton Rose Fulbright’s other teams ‘extra firepower,’ she says

Sam Sholli, June 04 2026

Sponsored

Map of Portugal in the colours of the national flag, bordered by the EU flag and euro notes on top

Sponsored by MFA Legal & Tech

Portugal’s housing package: a new stress test for free movement of capital?

Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test

Samuel Fernandes de Almeida, June 03 2026