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Tax & Legal

Tax & Legal

ECJ decision German CFC regulations to be published on 31 May 2018


The publication of the decision of the European Court for Justice (ECJ) in the Hornbach-Baumarkt case is scheduled for 31 May 2018. The case revolves around the question whether Section 1 of the Foreign Transaction Tax Act (“FTTA” – in the version in force in 2003) violates the freedom of establishment. The section in question calls for income corrections to be made on related party transactions which are not considered to have been concluded at arm’s length. Continue reading