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Foreign Real Estate
Investments in Germany
Sophisticated solutions in a complex legal environment.
Serious legal and tax advice in the land of smile.

• Please feel ...
Cross-border tax structuring in a nutshell:
Inbound investments in German real estate
- Acquisition
- Financing
- Dividend...
Please see an updated
and completed version
of this white paper at
http://www.scribd.com/
PUGNATORIUS_LTD
or at
www.pugnat...
www.PUGNATORIUS.com
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Real Estate Investment Guide Germany

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How to invest in German real estate. A legal and tax guide.

Germany, real estate, landkauf, land, building, german, investment, investitions

Published in: Business, Economy & Finance
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Transcript of "Real Estate Investment Guide Germany"

  1. 1. Foreign Real Estate Investments in Germany
  2. 2. Sophisticated solutions in a complex legal environment. Serious legal and tax advice in the land of smile. • Please feel free to contact us in our Bangkok office for questions, comments and other requests by phone or e-mail in Thai, English or German language. ! PUGNATORIUS Ltd. | International Lawyers
 29 Central World Tower | 999/9 Rama 1 Bangkok 10330 | Kingdom of Thailand
 +66 22072647 | lawyers@pugnatorius.com ! • PUGNATORIUS Limited is an independent legal practice 
 based in Bangkok, Thailand. The law firm provides inter-
 national corporations, investors and foreign law firms with
 premium legal and tax services relating to Thailand, Southeast Asia and offshore jurisdictions.
  3. 3. Cross-border tax structuring in a nutshell: Inbound investments in German real estate - Acquisition - Financing - Dividend flow - Exit / disposal „Independent third party“ Investor - Dividend taxation - Hybrid financing - Interest deduction of acquisition financing / interest barrier rules - Capital gain taxation / withholding taxation - Tax treatment of losses ! ! - European holding - Black listed countries - Low / no tax countries (Offshore) holding Management company - Foreign controlled corporations - Taxation of passive income (capital ! ! gains, dividend, interest) - Tax exemption for dividends from - Nothing (direct investmentI - Corporation (GmbH) - Partnership - Private equity funds Real estate entity Operating Company Lease Foreign management - Development - Add value - Tenancy - Tax driven portfolio - strategy REIT status Real estate asset - Land - Building ! ! ! ! participations / non-deductible expenses - Debt push down structures - Tax deductibility of maintenance - ! and repairs, depreciation allowances and financing costs interest capping rules (Zinsschranke) Special trade income tax deduction - Reduction of taxable basis - VAT implications - Registration duties - Real estate transfer tax blocker
  4. 4. Please see an updated and completed version of this white paper at http://www.scribd.com/ PUGNATORIUS_LTD or at www.pugnatorius.com
  5. 5. www.PUGNATORIUS.com
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