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Tax Bill 2010 includes CFC changes

01 December 2010


On October 29 2010, the Bundestag passed the Annual Tax Bill 2010 (for 2011) and forwarded it to the Bundesrat for final approval. One of the main features is a change to the CFC rules to counter a perceived abuse. The principle behind the CFC rules is to attribute passive income to the German parent if retained by a foreign subsidiary after effective taxation of less than...



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