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Tax & Legal

Tax & Legal

New decree by Federal Ministry of Finance extends motive test for escape from CFC taxation to third country situations


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. Continue reading