🇩🇪Germany

Fehlallokation von Principal und Income in Trusts

3 verified sources

Definition

Beneficiaries face pro-rata attribution of trust income under Außensteuergesetz even without distributions, plus Gift Tax on payouts. Poor principal/income allocation leads to incorrect transparency status and uncredited taxes.

Key Findings

  • Financial Impact: 20-30% tax on attributed income (e.g., 26.375% Kapitalertragsteuer + Solidaritatszuschlag; €100,000+ per €500,000 trust annually)
  • Frequency: Annual attribution + per distribution
  • Root Cause: Manual principal/income splits without BFH-compliant transparency tests

Why This Matters

This pain point represents a significant opportunity for B2B solutions targeting Trusts and Estates.

Affected Stakeholders

Erben, Begünstigte, Wirtschaftsprüfer, Steuerberater

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Financial Impact

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Current Workarounds

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Methodology & Sources

Data collected via OSINT from regulatory filings, industry audits, and verified case studies.

Evidence Sources:

Related Business Risks

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