OrbitaxGerman Federal Tax Court holds CFC rules not applicable in cases of administratively limited tax relief in order to comply with low taxation threshold
|Treaty Development|Germany-Ireland
On 3 May 2006, the German Federal Finance Court delivered a judgment in which it ruled that:
| - | German CFC rules are not applicable if an Irish intermediary company is not subject to low taxation (but instead to higher taxation) due to the application of Irish law providing for an official procedure in cooperation with th… |
