Taxation of black funds in Germany
In the most recent contribution to AGEFI (June 2015 edition), Patrick Goergen and Philippe Lacourt are commenting on the ECJ judgment of 21 May 2015 (C-560/13). The case concerned the taxation of revenues of a Caymand Islands investment fund for the years 1997 to 2003. The European Court of Justice has interpreted the wording "movement of capital" as it figures in the European treaties. German law had classified funds into "white", "grey" or "black" funds, according to the level of...
