On March 11, 2015 the German Supreme Tax Court ruled that income included in the tax basis of a German taxpayer under the German CFC rules acc. to Sec. 10 Para 1 Sent 1 German Foreign Tax Act will remain foreign source income. Because German trade tax is only on income generated in Germany such CFC add-backs are to be excluded from the German trade tax base acc. to Sec. 9 No 3 Sent 1 German Trade Tax Act.