Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/26669 
Year of Publication: 
2009
Series/Report no.: 
CESifo Working Paper No. 2624
Publisher: 
Center for Economic Studies and ifo Institute (CESifo), Munich
Abstract: 
The paper evaluates the working of German CFC rules that restrict the use of foreign subsidiaries located in low-tax countries to shelter passive investment income from home taxation. While passive investments make up a significant fraction of German outbound FDI, we find that German CFC rules are quite effective in restricting investments in low-tax jurisdictions. We find evidence that the German 2001 tax reform, which unilaterally introduced exemption of passive income in medium- and high-tax countries, has led to some shifting of passive assets into countries for which the exemption was previously limited.
Subjects: 
foreign direct investment
CFC regulation
passive investment
JEL: 
H25
H73
Document Type: 
Working Paper
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