16.06.2022 EU General Court: UK CFC rules in force until 2018 are State ... In a recent judgment the General Court of the EU dismissed the applications of two joint cases seeking annulment of the European Commission’s State aid decision on the UK Controlled Foreign Company (CFC) rules in force until 31 December 2018. Categories: From EuropeKeywords: CFC provisions, state aid
18.06.2021 UPDATE: Bundestag approves Tax Haven Defence Act On 10 June 2021, the Bundestag approved the "Act to avert tax avoidance and unfair tax competition and to amend other laws". In doing so, the Bundestag followed the recommendation of the Finance Committee. Categories: Tax & Legal News, LegislationKeywords: tax haven, CFC provisions, tax avoidance
06.11.2019 CFC rules considered to be in line with EU law Following a ruling by the European Court of Justice (ECJ) earlier this year, the Supreme Tax Court held in its decision of 31 October 2019 that the incorporation into the tax base of controlled company income from invested capital from an intermediary company domiciled in Switzerland in the financial year 2006 may restrict the free movement of capital, but it is justified through compelling reasons of public interest and does not therefore contravene EU law. Categories: Supreme Tax Court casesKeywords: CFC provisions, free movement of capital ...
06.06.2018 German CFC rules may be compatible with EU law The European Court of Justice held that the German CFC regulations – as such – do not generally pose a restriction on the freedom of establishment. Categories: European Court of JusticeKeywords: CFC provisions, freedom of establishment ...
09.01.2011 Active business can be contracted out The Supreme Tax Court has held that a Dublin docks reinsurance company that subcontracted its operation under a management agreement was an active business within the meaning of the Foreign Tax Act. Categories: Supreme Tax Court casesKeywords: Active business, contracted out, CFC pro ...
