The Resource The German CFC rules : overview, deficits and reform proposals

The German CFC rules : overview, deficits and reform proposals

Label
The German CFC rules : overview, deficits and reform proposals
Title
The German CFC rules : overview, deficits and reform proposals
Creator
Subject
Language
eng
Summary
German controlled foreign company (CFC) rules rank among the oldest in the world. They have been in existence for more than forty years. Today, the body of CFC rules is increasingly accused of being outdated, vague and ambiguous, and no longer in alignment with the needs of a modern globalized world economy. Consequently, not only taxpayers and their advisors but also tax authorities and tax courts face dramatic und partly unsolvable application problems. Some particular German CFC-provisions have been said to be inapplicable by all parties involved. With this background in mind, this article revisits the most challenging problem areas and offers possible solution approaches. It also identifies possible tax risks in connection with the German CFC legislation and therefore may turn out for investors as a decision making support tool
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 42 (2014),
http://library.link/vocab/creatorName
  • Kraft, G
  • Moser, T
  • Hentschel, S
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • risk management
  • expenses
Label
The German CFC rules : overview, deficits and reform proposals
Instantiates
Publication
Label
The German CFC rules : overview, deficits and reform proposals
Publication

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