26. Oktober 2011 Private equity fund earns trading income The Supreme Tax Court has held that a closed private equity/venture capital fund is a trading venture taxable in its country of establishment. If it is exempt there by reason of local regulation, its income does not revert to German taxation by virtue of treaty or statutory provisions on conflicts of qualification. Kategorien: Supreme Tax Court casesSchlagwörter: Private Equity, treaty override, start-u ...