German rules pierce corporate veil

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

German rules pierce corporate veil

The German CFC regime was, like many others, founded on the principles of the US’ Subpart F. Since its inception in 1972, the rules have been adapted to focus on capital investments. Mark Smith and Diether Laudan of Ernst & Young in Stuttgart explain the rules

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login
more across site & shared bottom lb ros

More from across our site

Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention
Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
User-friendly digital tax filing systems, transformative AI deployment, and the continued proliferation of DSTs will define 2026, writes Ascoria’s Neil Kelley
Case workers are ‘still not great’ but are making fewer enquiries, making the right decision more often and are more open to calls, ITR has heard
There is a shocking discrepancy between professional services firms’ parental leave packages. Those that fail to get with the times risk losing out in the war for talent
Winston Taylor is expected to launch in May 2026 with more than 1,400 lawyers across the US, UK, Europe, Latin America and the Middle East
They are alleging that leaked tax information ‘unfairly tarnished’ their business operations; in other news, Davis Polk and Eversheds Sutherland made key tax hires
Overall revenues for the combined UK and Swiss firm inched up 2% to £3.6 billion despite a ‘challenging market’
Gift this article