On December 10, 2019, the German Ministry of Finance published a first draft of a reform of its controlled foreign corporation (CFC) taxation. Even though Germany had already implemented CFC taxation in 1972, a reform was necessary because the existing ... (more)
The European Court of Justice ruled (ECJ 13 November 2019 – C-641/17) that the definitive withholding tax levied on German dividends received by foreign pension funds infringes the principle of the free movement of capital (Article 63 of the Treaty on the Functioning of ... (more)
On November 29, 2019, the so-called Annual Tax Act 2019 passed the German Bundesrat (upper house) and is expected to be enacted before the end of this year. The Act introduces, inter alia, the requirement to capitalise fund structuring costs, ... (more)