The dual taxation of companies is based on the uniform principle (taxation of the natural person behind the sole proprietorship) and the separation principle (taxation of the corporation and the shareholders as two independent tax recipients). These principles form the basis for the conception of a legally neutral and uniform corporate taxation.
A partnership tax would cover the natural persons behind it in all legal forms. Taxing the company independently of the owners corresponds to the operating tax. Applying one of these models would abolish dual corporate taxation.
The Brühl recommendations, however, provided for the two taxation concepts to coexist. However, the taxation of private companies in national and international tax law (external tax law) is particularly problematic.