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 legislation is not in line with the requirements of the Anti-Tax-Avoidance Directive (ATAD) of the European Union in every aspect. At first glance, the proposed amendments look rather minor, but after a closer look it becomes evident that the reform has the potential to significantly increase compliance requirements, in particular for German investors in investment funds.