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V0167-25 ·13 February 2025 ·consulta-vinculante Low impact
Tax

Determination of the Non-Resident Income Tax taxpayer in German real estate investment funds

The DGT determines that the fund, not the manager, is the taxpayer due to a fiduciary relationship.

In 6 key points

How it affects those involved

The liability for IRNR falls on the real estate fund, not the management company, because of the fiduciary relationship.

Lifecycle

2025-02-13PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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