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Presumptions and CFC rules

Original: “Vermutungen und Hinzurechnungsbesteuerung”

On July 19, 2023, the Federal Ministry of Finance published a draft of an application letter on the new German Income Tax Act (AStG), in which it also deals in more detail with the presumption in Sec. 7 (4) Sentence 2 AStG and its rebuttal. Both the statutory presumption itself and the Federal Ministry of Finance’s comments are rather questionable.

in: DER BETRIEB Steuerboard, www.der-betrieb.de, August 25, 2023
Authors: Ronald Buge
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