Gordon Group’s English-language Questions & Answers says investors in commercial real estate are generally expected to provide 100% equity in the current environment. It also describes structuring equity as a shareholder loan for international buyers without German tax residence, with interest payments exempt from local income tax.
The same page says this approach is particularly relevant for investors whose country of citizenship does not tax foreign-source income earned by its residents. These are the site’s statements, not an individual tax assessment.
Sources: Gordon Group, English-language site.