Recent challenges for inbound PE structures in Germany

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Recent challenges for inbound PE structures in Germany

June 30 2012
pe-puff.jpg

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

FeatureSponsoredITR MagazineJuly / August 2012
more across site & shared bottom lb ros

More from across our site

Transfer Pricing
Jamaica
OECD hails Jamaica’s TP overhaul amid $7.7bn revenue intake
The country has overseen better audit procedures and demonstrated commitment to acting as a 'regional leader' on international tax matters, the OECD said
Sam Sholli, April 09 2026
Direct Tax
Google
Exclusive: UK tax barrister and campaigner renew war of words
Barrister Setu Kamal and policy guru Dan Neidle have clashed over the former’s legal action against Google, described as ‘bonkers’ by Neidle
Sam Sholli, April 09 2026
Direct Tax
India Mauritius
GAAR grandfathering ‘restored’ pursuant to Tiger Global: analysis
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Sanjay Sanghvi, April 08 2026
Direct Tax
Baker McKenzie
Baker McKenzie appoints ex-KPMG lawyer as Austrian tax head
Dual-qualified corporate tax specialist Christoph Schimmer joins the firm after stints at Deloitte, Cerha Hempel and DLA Piper
Tom Baker, April 08 2026
Direct Tax
Global digital
Pillar two and the new global tax disorder
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Renáta Bláhová, April 06 2026
Direct Tax
marco sandoli resized.jpg
Trust is a tax virtue, says Marco Sandoli
LED Taxand’s partner tells ITR about entrepreneurial inspirations, the importance of people skills, and what makes tax cool
April 06 2026
Direct Tax
ryan office pic resized.jpg
A taxing week: Three cheers for the firms betting on real estate
Shiny new offices like Ryan’s in London Bridge aren’t just a cost – they signal that a firm is willing to align with its clients’ interests
Tom Baker, April 03 2026
Direct Tax
Gdansk, Poland - May 8, 2022: Logo and sign of Deloitte, multina
This week in tax: Deloitte UK appoints tax specialist as CEO
Darren Graves will succeed Richard Houston, who is set to lead Deloitte EMEA; in other news, Morgan Lewis hired a three-partner tax team in New York
Sam Sholli, April 03 2026
Transfer Pricing
india.jpg
India announces record number of APAs for 2025/26 financial year
India also signed its first-ever bilateral APAs with France, Ireland, Indonesia and Sweden last year, the CBDT revealed
Sam Sholli, April 02 2026
Direct Tax
Chile tax
Chile’s GAAR one year on: enforcement, sustainability and limitations
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
Patricio Casas Farías, April 02 2026
Gift this article