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A no-PE structure refers to a corporate structure that avoids a permanent establishment, usually in Germany. This is particularly important for foreign companies with domestic real estate. A foreign real estate company is subject to corporation tax and the solidarity surcharge, but not to trade tax.

In the USA, the Limited Liability Company (LLC) is regarded as a form of company that is easy to set up, flexible to handle and yet offers personal limitation of liability for its shareholders (members). Special features must be observed if its shareholders are resident in Germany. Some of the special features are described in two articles.

For foreign investors Germany’s real estate property is still attractive although property prices are still rising. Foreign investors have to consider legal and tax issues in Germany. This article covers 10 main tax issues. (1) German real estate and taxes …