The Shielding Effect of EU/EEA Foundations in Multi-Layer Structures in the Context of Section 15 of the German Foreign Transactions Tax Law

Journal
Germany
European Taxation 2015 (Volume 55), No. 10
This note looks at the potential use of EU/EEA foundations as a shield for earnings of lower-tier intermediary companies and foreign foundations with regard to the German taxation of foreign family foundations, as well as the German CFC rules.