Federal Ministry of Finances clarifies application of CFC rules

On 8 January 2007, the Federal Ministry of Finance issued a circular clarifying the application of German CFC rules to pending cases. The circular is a reaction to the ruling of the European Court of Justice in the case Cadburry-Schweppes (C-196/04).
The circular establishes that in conformity with EU law, no CFC taxation may be applied if the taxpayer p…
Continue Reading