Draft for a revision of the imputation taxation for foreign family foundations pursuant to Section 15 AStG

The draft revision of the imputation tax for foreign family foundations (Section 15 AStG) envisages far-reaching changes.

The key points of the planned reform:

• Low tax threshold: Imputation only applies to taxation below 15 percent.
• Extended circle: The relevant family circle is extended to include related persons.
• New proof of relief: The regulations on proof of relief will be revised.

The reform is intended to standardize the regulations and increase legal certainty. Those affected must urgently prepare for possible changes.