Abstract (eng)
In these times of the integration of international markets, capital flow is a
permanently increasing process. Cross-border investments can be implemented via
various entities, for example via partnerships structures and take place in more than
two countries, so called triangular cases. Since there is no uniform tax treatment of
partnerships among domestic tax regimes, conflicts of qualification of these entities
can easily occur. As a consequence of such conflicts are often double taxation or
double no taxation.