Axel Schilder and Martin Wolff discuss (real estate) tax issues in the context of the contribution of shares in real estate funds to a Special-AIF, which is structured as a Co-ownership Fund. The co-ownership fund (Miteigentumsfonds) is becoming increasingly important in practice as a structural alternative to the trust solution (Treuhandfonds) in Germany. Axel Schilder and Martin Wolff take this development as an opportunity to discuss (real estate) tax issues in the context of the contribution of shares in real estate funds to an open-ended domestic special AIF, which is structured as a co-ownership fund. The current tax implications and any existing legal uncertainties regarding the use of co-ownership funds for indirect real estate investments are identified and analyzed.