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
- T. Moser; S. Hentschel
- European Taxation, 2015 (Volume 55), No 10
- 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.