„Special Allocations" im deutschen Ertragsteuerrecht

The tax effectiveness of profit distribution agreements in partnerships is of high academic interest and practical relevance. This publication examines the largely unresolved question of whether special allocations of individual tax items is possible under German tax law.

In particular, the author examines

• relevant cases of special allocations and drafting guidance,
• the limits of profit distribution agreements under German partnership law,
• the limits of tax effectiveness in co-entrepreneurships and asset-managing partnerships and
• developments resulting from the recent reform of German partnership law (MoPeG).