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Germany - The Shielding Effect of EU/EEA Foundations in Multi-Layer Structures in the Context of Section 15 of the German Foreign Transactions Tax Law

Country:
Germany
Author:
T. Moser; S. Hentschel
Issue:
European Taxation, 2015 (Volume 55), No 10
Published:
10 September 2015
This note looks at the potential use of EU/EEA foundations as a shield for earnings of lower-tier intermediary companies and foreign foundations with regard to the German taxation of foreign family foundations, as well as the German CFC rules.
 
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