Many private equity funds, including real estate private equity funds, will not fall under the reporting requirements under the German Investment Tax Act (GITA), but will qualify as limited partnerships under the general reporting requirements of the German General Fiscal Code (GFC), explain Simone Stockmar and Friederike Schmitz of Bödecker Ernst & Partner.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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