ECJ: Passive income attribution from controlled companies re ...
The European Court of Justice has held that the German provision for the taxation of controlled company income from invested capital from outside the EU might fall under the “grandfather” clause of Art 64 TFEU, provided the German legislation has remained substantially unchanged since that date. It is now for the Supreme Tax Court to decide finally whether this is the case.
Kategorien: European Court of Justice
Schlagwörter: standstill clause, foreign passive incom ...