A UK resident is the 'limited partner' in a Kommanditgesellchaft (KG). As I understand it this means that this person's liability is limited although there are other partners whose liability is unlimited.
No less an authority than Wikipedia tells me that the KG is not in itself an entity, although it has lots of features of one. It can have rights, assets and liabilities.
Suppose the UK resident who earns a distribution from this business is something of a sleeping partner and is not actively involved in the business day-to-day.
The distribution to the UK resident, then: like a dividend, taxable in the UK? Or like the profits of a business based in Germany, taxable in Germany since there is no 'permanent establishment' in the UK where the UK resident is doing any work for it?
Very grateful for a vote from anyone who has dealt with such a beast before. Or, frankly, a vote from anyone at all.
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A KG is treated as transparent for UK tax purposes according to this:
https://www.gov.uk/hmrc-internal-manuals/international-manual/intm180030