CFC Exemption: New Tax Options for Trusts & Foundations
International Tax Law Update 2024 CFC Exemption: New Tax Options for Trusts & Foundations
In a landmark judgment dated 3 December 2024, the German Federal Fiscal Court (Bundesfinanzhof) opened the door for German-resident beneficiaries of third-country family trusts, family foundations, and similar structures to potentially be exempt from German CFC (Controlled Foreign Corporation) taxation.
Christian Kempges
Marie Christine Waldens
| 2 min read |