Level of the partnership
Step 1 – Determination of income at the level of the partnership:
In general, the determination of income at the level of the part-
nership follows the same rules as the determination of income
for corporations. However, some specifc features must be
considered:
Example
A and B are business partners, each holding a 50% interest in
A&B OHG, a general partnership. In the 2014 assessment peri-
od, the OHG generates a profit from commercial business activ-
ity in the amount of 100. The proft from commercial business
activity includes a remuneration of 30 for A’s work as managing
director and interest expense in the amount of 20 in connection
with a shareholder loan provided by B.
For example, if the acquisition costs exceed the carrying amount
of equity attributable to the partner, it is necessary to recognize
the excess amount in a supplementary tax balance sheet
(Ergänzungsbilanz).
Special partner remuneration (Sondervergütungen) paid by the
partnership to its partner for services (e. G. Directors’ remunera-
tion), loans (interest), and the use of assets (rental expenses) are
deductible in determining the income of the partnership.
The income is allocated to the partner in accordance with the
applicable profit allocation key.
EU Forecast
euf:ba.18g:6/nws-01