BFH confirms company-related control requirement for the switching clause pursuant to Section 20 (2) German Foreign Tax Act (AStG) - Part II

Following Part I of the article on the BFH ruling of April 8, 2025 on the application of the switching clause (Section 20 (2) AStG), Part II now examines the possible effects on trade tax. The focus is on private equity structures and the question of whether and under what conditions trade tax reductions on income from investments in foreign partnerships are still possible.