Tax deferral model
A tax deferral model is in accordance with § 15b EStG ago when tax benefits in the form of negative due to a model-based design of income to be achieved. This is the case if the taxpayer is to be given the option of offsetting losses against other income at least in the initial phase of the investment on the basis of a ready-made concept. It is irrelevant which regulations the negative income is based on.
Losses in connection with a tax deferral model may not be offset against income from commercial operations or income from other types of income ; they may not be deducted according to § 10d EStG. However, the losses reduce the income that the taxpayer earns in the following financial years from the same source of income. However, this only applies if, within the initial phase, the ratio of the sum of the forecast losses to the amount of the subscribed and, according to the concept, also to be raised capital or, in the case of individual investors, the equity capital employed, exceeds 10 percent.