Die Besteuerung der Kommanditgesellschaft auf Aktien und ihrer Gesellschafter im internationalen Steuerrecht

As a hybrid company form between a corporation and a partnership, the partnership limited by shares moves between non-transparent and transparent taxation. It has a special position in the domestic dualism of corporate taxation. This impacts the international tax law as well. The study examines the effects of cross-border activities of a partnership limited by shares and its shareholders under international tax law on the basis of inbound and outbound constellations and analyses the application of uni- and bilateral regulations for avoidance of double taxation. The result is an “attribution model” which, in the author’s opinion, represents a system-compliant solution for the partnership limited by shares in a cross-border context.