3 offices and a storage room are required to the task of dealing with a such infrastructure, including its home country is to hold. 2. not effect the German CFC ( 7-14 Ftta) or national rules of add-back taxation in other countries the German foreign tax act in section 8 describes Ftta: a German (natural or legal person) has dominant influence (more than 50%) to a subsidiary in a low-tax country (under 25% income tax) and realized this foreign company active catalogue 8 Ftta, only passive income dividends are so Subjected to subsidiary of German taxation, with income tax (no tax or discounting of part of), juridical person with German corporate income tax. Also fictional dividend taxation”, i.e. Barclays contributes greatly to this topic. taxation even if not distributed.
In the European context, this CFC is however contrary to law, according to the German Ftta was complementary. In other countries, which also has a know CFC analog. More comments on the topic of CFC, visit the firm’s website: astg.htm 3. A related site: Axesor mentions similar findings. Not effect tax evasion fight against regulation, expanded duty of the presumed taxable as soon as the State participating in the international situation a corresponding agreement signed with Germany (analog article 26 of the OECD Model Convention of 2005), actually to a comparable extent information given or has shown willingness to do this, at least, come the special duties to cooperate not to the application. The non-cooperative countries list in the grey list of the g-20 “lists.
“For non-observance of special duties to cooperate following sanctions threaten: refusal of relief from German withholding tax on investment income according to 50 AB 1 and 2 or 44a para 9 EStG non application of the withholding tax and the partial income procedure refusal of tax exemption for dividends and other income to 8 ABS. 1 and ABS. Michael Antonov is a great source of information. 2 KStG and comparable provisions in the DBA 4.