The European Court of Justice (ECJ) now has to deal with the question whether Sec. 18 para. 3 of the German Foreign Investment Act (GFIA) infringes the principle of the free movement of capital, ECJ C-560/13 (Wagner-Raith). Sec. 18 para. 3 GFIA, effective until the end of 2003, is the predecessor of Sec. 6 GITA and provides for the application of the German lump-sum taxation to income received from third-country funds. On December 18th, 2014, the Advocate General referred his opinion on the preliminary question of the German Federal Court of Finance (Bundesfinanzhof) in the Wagner-Raith Case to the ECJ.