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Germany - German CFC Legislation 2011: New Anti-Avoidance Provisions and Tax Planning Opportunities

Country:
Germany,Malta
Author:
T. Kollruss
Issue:
European Taxation, 2011 (Volume 51), No 1
Published:
21 December 2010
The German Annual Tax Act 2010 tightens the CFC legislation with regard to foreign jurisdictions (especially Malta) that provide a credit or tax refund at the shareholder level. In Malta, for example, a CFC pays tax at a high rate (thus avoiding the German CFC provisions). Its shareholders, however, benefit from a tax refund, reducing the overall level of taxation significantly. The author highlights amendments to the CFC rules to close this loophole and tax planning opportunities that remain.
 
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