(Denied) tax neutrality of capital repayments

In recent years, the taxa­tion of private equity funds and of the share­hol­ders of private equity funds who are liable to tax in Germany has incre­asingly become the focus of the tax autho­ri­ties. In the area of tax audi­ting, specia­li­zed teams have been set up with corre­spon­ding person­nel rein­force­ments, which are inten­si­vely trai­ned by more expe­ri­en­ced audi­tors with regard to the special features of private equity struc­tures. — Howe­ver, tax advi­sors have recently also been confron­ted more and more with extreme posi­ti­ons on the part of the tax authorities.