Final application decree on the Foreign Tax Act reduces the administrative burden of add-back declarations
At the end of last year, the Federal Ministry of Finance published the application decree on the CFC Act. There is positive news to report: (1) Investors, for whom the attributed income does not trigger a tax liability, do not have to submit a CFC return (for example, pension funds and investment funds), (2) for the calculation of the degree of control, there is no presumption of acting together with the other partners of a partnerships if partnership interest does not exceed 5 percent.
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