Außensteuergesetz

German Foreign Tax Act and Luxembourg Funds

TAX, Außensteuergesetz, CFC, Peter Kleingarn

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 …

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German Investment Tax Act vs. German Foreign Tax Act

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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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