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Federal Ministry of Finances clarifies application of CFC rules

|Approved Changes|Germany
Germany

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…

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