DT7906 - Germany, Federal Republic of: Partnerships

Article 2(1)(h)(iii) provides that a partnership is a resident of the country in which its place of effective management is situated.

A United Kingdom resident partner is chargeable only to United Kingdom tax on his share of the partnership profits unless the profits are derived from a permanent establishment in Germany.

In that case the partner is also chargeable to German tax on his share of the profit attributable to the permanent establishment and he will be entitled to credit for any German tax against the United Kingdom tax on those profits.