Last week, the Düsseldorf Fiscal Court published a decision in which it again classifies distributions from a Luxembourg SICAV organised as a corporation as qualifying intercompany dividends to be exempted in Germany under the old DBA Luxembourg applicable until 2013 (2 K 3874/15 F). For the first time, however, the Fiscal Court had the opportunity in these proceedings to determine that this also applies if the distributions consist of income generated by way of bondstripping. The tax authorities have lodged an appeal with the Federal Fiscal Court (I R 8/19).