Suchergebnisse für: `motive-test` (2 gefunden)

1. 17. Juni 2021

   New decree by Federal Ministry of Finance extends motive tes ...

   On 17 March 2021, the German Federal Ministry of Finance (BMF) published a decree on the application of Section 8 (2) of the Foreign Tax Act (AStG) which stipulates the “motive test” taxpayers have to meet to escape controlled foreign company (CFC) taxation.

   Kategorien: Official Pronouncements

   Schlagwörter: CFC taxation, motive test
2. 27. September 2018

   German trade tax exemption for third country dividends in br ...

   On 20 September 2018, the European Court of Justice held that the “activity clause” in the German trade tax act for third country sourced dividends is contrary to the free movement of capital (Art. 63 of the Treaty on the Functioning of the EU - TFEU).

   Kategorien: European Court of Justice

   Schlagwörter: trade tax exemption, third country divid ...