Amsterdam, 22/04/2016 (Agence Europe) - Germany is insisting on the application within the EU of the rules on 'controlled foreign companies' ('CFC') discussed in the framework of the proposed anti-tax avoidance directive (ATAD).
Readers may recall that these rules reallocate the income of low-taxed controlled subsidiaries to the parent company. In this scenario, therefore, the parent company has to pay tax on this income in the state in which it has its headquarters, generally high-tax...