No separate and uniform determination for a single-person asset management limited partnership (Vermögensverwaltungs-KG)

Where an asset-managing partnership has, in economic substance, only a single beneficial partner, is a separate and uniform tax assessment procedure required at all? In a recent decision concerning a share disposal under section 17 of the German Income Tax Act (Düsseldorf Tax Court, judgment of 13 July 2026 – 14 K 1640/24 F), the Düsseldorf Tax Court says no, rejecting the tax authorities’ position because no more than one person was entitled to the income. The ruling is highly relevant for single-investor asset-managing structures in practice.