In its recently published decision the Federal Finance Court stated that tax assessment concerning the uniform and separate determination of profits according to Sec. 180 (1) No. 2a General Fiscal Code of a foreign partnership has to be addressed to the partners of the partnership. Tax returns addressed to the foreign partnership as such are void by law.

This is a change to what the Court has ruled before (I R 33/06 BFH NV 2007, 2236),  where the Court stated the tax assessments had to be addressed to the partnership itself.