COMPARISON OF THE TAXATION REGIMES OF PARTNERSHIPS IN EUROPE

MATTHIAS BUSCHHAUS

https://doi.org/10.53465/ER.2644-7185.2025.2.76-98

Abstract: Paper categorises the German taxation regime for partnerships in the European context. In particular, the German option model introduced on 1 January 2022, under which partnerships can choose whether they are taxed like German corporations or - as previously - transparently, is compared with other European taxation methods for partnerships and a detailed comparison is made with France, which also has an option model. The comparison includes both the transparency principle applied to date and a comparison of the opportunities and risks of the option models. In addition, an assessment of the respective company law in Germany and France is made. The comparison focuses on the tax risks, but also on the complexity of both systems and the associated advisory costs, which can have a negative economic impact on the financing of partnerships. To summarise, it can be said that the French option model has slight advantages, as tax law in Germany is significantly more complex and requires more advisory support, and the risk of retroactive taxation can significantly increase the tax burden.

Keywords: Options models, Partnerships, Taxes, European comparison, Law

JEL Classification: H20, H21, H25

Fulltext: PDF

Online publication date: 25 June 2025

To cite this article (APA style):

Buschhaus, M. (2025). Comparison of the taxation regimes of partnership in Europe. Economic Review, 54(2), 76 ─ 98. https://doi.org/10.53465/ER.2644-7185.2025.2.76-98

Publisher: Bratislava University of Economics and Business

ISSN 2644-7185 (online)

License:

This work is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License.