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Singapore Germany Double Tax Agreement

Hello, a German citizen has his residence in Singapore. He has rental income in Germany and is now therefore subject to limited tax liability in Germany.

He now establishes a GmbH in Germany. He holds 100% of the shares. This GmbH buys and rents out real estate. The GmbH is purely active in asset management. It therefore pays 15% corporation tax plus solidarity surcharge.

What additional taxes are now incurred if they distribute their profits to the shareholder in the form of dividends?

What taxes are incurred if the shareholder provides a loan to the GmbH?

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