Substance requirements for foreign companies - too much of a good thing?

It is a perennial tax issue for private equity companies with international structures: How much “substance” do the individual companies have to bring to the table? In recent years, the German tax authorities often saw undesirable tax advantages for companies due to existing double taxation agreements, and legislators responded with new requirements. However, these often ended up before German tax courts. What companies are currently facing and what they should be prepared for was the topic of a panel discussion at this year’s Munich Private Equity Training of P+ Training.