Following some detailed submissions. Companies in the EU, formed by residents in the EU: as a parent right attacks the EU freedom of establishment or judgments of the European Court of Justice on the freedom of establishment. No company is the existence of a proper foundation of a company under the law of the Member State, no matter what business the company has and no matter whether she actually does this (permitted or not permitted) business. In any case a lump-sum non-recognition does not take place. Accordingly, the existence of a licence society by the case-law of the BFH therefore only in exceptional cases is assumed (Prof. Dr.
Thomas Reith, International tax law, Verlag Vahlen, page 71; Federal fiscal judgment of the 23.06.1992,BStBl 1992 II p. 972). The EU freedom of establishment allows even the targeted exploitation of the tax gap through establishment of EU subsidiaries (ruling Cadburry Schweppes), only minimal substance within the meaning of more than a mere letter box is required. Also: No effect of the German CFC ( 8 Ftta), effect of EU parent subsidiary directive or EU merger directive. Usually present low-tax countries in the EU are positive effect of a double taxation agreement: Cyprus and Bulgaria with 10% income taxes without pads, Madeira and ZEC (Special Canary, zone) 5% with conditions. Incorporations DBA facts shielding effect of double taxation agreement (DBAs) available, E.g. against high withholding tax on dividends the existence of a permanent establishment in the home and abroad is defined exclusively through 5 DBA, not national law (in Germany 12 / 13 AO). Therefore a warehouse, a representative office or permanent representative of the subsidiary outside of the State raises no permanent establishment, so vice versa to the non-DBA facts effect of the German CFC after 8 Ftta, other countries know about similar arrangements no effect of EU freedom of establishment or judgments of the European Court of Justice on the freedom of establishment no effects EU merger directive, or EU parent subsidiary directive low-tax countries in the DBA facts for German clients are: UAE (no taxes), Switzerland (15.5% in the canton of Zug), Singapore or Mauritius.