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Making Germany's CFC Rules Effective Again

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Making Germany's CFC Rules Effective Again ESCUELA INTERNACIONAL DE DOCTORADO Programa de Doctorado en Ciencias Sociales Making Germany’s CFC Rules Effective Again: A Comparative Analysis to Spain’s and UK’s CFC Rules to Find the Best ATAD Compliant Approaches Provided in the OECD/G20’s Report on Designing Effective CFC Rules Autor: RA, StB Peter Wenzel Directores: Prof. Dra. Mercedes Carmona Martínez Prof. Dra. Rocío Arteaga Sánchez Prof. Dr. Roland Wolf Murcia, Febrero de 2019 ACKNOWLEDGMENTS First of all I would like to thank Prof. Dra. Rocío Arteaga Sánchez and Prof. Dr. Roland Wolf. Their advice regarding the structure of this thesis, the discussion and review of its content, as well as their guidance regarding the formal requirements was extremely helpful, especially because both of them responded very promptly to my questions and queries. I would also like to thank Prof. Dra. Mercedes Carmona Martínez as well as Prof. Dr. Alexander Zureck for the great organization of numerous academic events in Murcia and Essen, but especially for their help during the last weeks with the deposit of this thesis. Completing this thesis would not have been possible without the support and encouragement of my beloved wife Jaquelinne De León Ríos Wenzel as well as of my daughter Anika Wenzel de León. They passed countless weekends largely on their own to allow me to develop this thesis. A big thank you therefore as well as for your support and encouragement throughout my preceding exams. Furthermore, I must express my great gratitude to my parents, Ursula and Dr. Peter Wenzel. Their support and encouragement throughout my whole education was exceptional. I could visit a school in New Zealand, study semesters abroad in Spain and Switzerland and work as an intern in Paraguay and Peru. Without my parents, such great experiences would never have been possible. Finally, I am indebted to my colleagues at EY. They allowed me to take one year off work to develop large parts of this thesis. As a consequence, for some of them, the workload was surely more than usual. Thank you for making this possible. Further family members and friends supported my doctoral studies in various ways. I would like to thank all of them. Witten, 25 February 2019 RA, StB Peter Wenzel CONTENTS 1. Introduction ................................................................................................. 13 1.1. Structurings without CFC rules ........................................................ 13 1.1.1. Tax deferral ...................................................................................... 14 1.1.2. Tax avoidance .................................................................................. 15 1.2. Overview on German CFC rules ....................................................... 16 1.2.1. Systematical classification .............................................................. 16 1.2.2. Conditions and legal consequences .............................................. 16 1.3. Issues of the German CFC rules ........................................................ 17 1.3.1. Issues ................................................................................................. 17 1.3.2. Legal development of German CFC rules ................................... 17 1.4. International developments ............................................................... 19 1.4.1. BEPS .................................................................................................. 19 1.4.2. ATAD ................................................................................................ 20 1.5. Research goal ....................................................................................... 20 1.6. Research method ................................................................................. 21 2. Conditions for a CFC taxation ................................................................... 23 2.1. Rules for defining a CFC .................................................................... 23 2.1.1. BEPS .................................................................................................. 23 2.1.2. ATAD ................................................................................................ 26 2.1.3. Germany ........................................................................................... 27 2.1.4. Spain .................................................................................................. 47 2.1.5. UK ...................................................................................................... 55 2.1.6. Recommendation............................................................................. 61 2.2. CFC exemptions and threshold requirements ................................ 65 8 2.2.1. BEPS .................................................................................................. 65 2.2.2. ATAD ................................................................................................ 69 2.2.3. Germany ........................................................................................... 71 2.2.4. Spain .................................................................................................. 84 2.2.5. UK ...................................................................................................... 88 2.2.6. Recommendation........................................................................... 104 2.3. Definition of CFC income................................................................. 109 2.3.1. BEPS ................................................................................................ 109 2.3.2. ATAD .............................................................................................. 114 2.3.3. Germany ......................................................................................... 115 2.3.4. Spain ................................................................................................ 153 2.3.5. UK .................................................................................................... 163 2.3.6. Recommendation........................................................................... 192 3. Consequences of a CFC taxation ............................................................. 199 3.1. Rules for computing income ............................................................ 199 3.1.1. BEPS ................................................................................................ 199 3.1.2. ATAD .............................................................................................. 199 3.1.3. Germany ......................................................................................... 200 3.1.4. Spain ................................................................................................ 203 3.1.5. UK .................................................................................................... 205 3.1.6. Recommendation........................................................................... 208 3.2. Rules for attributing income ............................................................ 208 3.2.1. BEPS ................................................................................................ 208 3.2.2. ATAD .............................................................................................. 209 3.2.3. Germany ......................................................................................... 210 3.2.4. Spain ................................................................................................ 214 3.2.5. UK .................................................................................................... 215 9 3.2.6. Recommendation........................................................................... 225 4. Rules to prevent or eliminate double taxation ...................................... 227 4.1. BEPS .................................................................................................... 227 4.2. ATAD .................................................................................................. 227 4.3. Germany ............................................................................................. 228 4.3.1. Rules ................................................................................................ 228 4.3.2. Issues ............................................................................................... 230 4.3.3. ATAD compliance ......................................................................... 232 4.4. Spain .................................................................................................... 232 4.4.1. Rules ................................................................................................ 232 4.4.2. Issues ............................................................................................... 233 4.4.3. ATAD compliance ......................................................................... 233 4.5. UK ........................................................................................................ 234 4.5.1. Rules ................................................................................................ 234 4.5.2. Issues ............................................................................................... 236 4.5.3. ATAD compliance ......................................................................... 236 4.6. Recommendation .............................................................................. 236 5. Conclusions, limitations and future
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