German Foreign Tax Act and Luxembourg Funds Publishing with authorisation of Agefi, Avril 2023 Effective 1 January 2022, investors in Luxembourg investment funds resident in Germany may be subject to controlled foreign corporation (CFC) rules under the German Foreign Tax Act if the investment fund invests in assets through subsidiaries not resident in Germany. CFC …
CSSF-SFDR Data Collection – Deadline for Submission of Initial Reports: 15 June 2023 The CSSF has published a communication on SFDR data collection on 24 March 2023 in accordance with its Communication dated 27 July 2022, in which it announces a data collection exercise in relation to the precontractual disclosures on Regulation (EU) 2019/2088 on …
German Foreign Tax Act and Luxembourg Funds Executive Summary Effective 1 January 2022, investors in Luxembourg investment funds resident in Germany may be subject to controlled foreign corporation (CFC) rules under the German Foreign Tax Act if the investment fund invests in assets through subsidiaries not resident in Germany. CFC rules apply if an investor resident in …
Precedence of the German Investment Tax Act Over the German Foreign Tax Act Under the ATAD Implementation Act Background On 25 June 2021, the German Federal Council (Bundesrat) approved the Act on the Implementation of the Anti-Tax Avoidance Directive, which had already been published in the Federal Law Gazette (Bundesgesetzblatt) on 30 June 2021. The …
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