17.06.2021 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. Categories: Official PronouncementsKeywords: CFC taxation, motive test