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Section 12 (4) of the Corporation Tax Act last applicable for the fiscal year 2020

§ 12 para 4 was repealed in 2021. At the same time, the following changes were introduced:

§ 34 para 3c KStG
§ 8 para 1, as amended by Article 3 of the law of June 25, 2021 (BGBl. I p. 2056), is also applicable for assessment periods prior to 2021

§ 34 para 6d KStG
§ 12 para 4, in the version applicable as of June 30, 2021, is to be applied for the last time for the assessment period of 2020.

§ 8 para 1 sentence 4 KStG
In the case of corporations under § 1 para 1 with headquarters abroad, whose place of management is located domestically and which, due to lack of legal capacity under domestic corporate law, are not treated as legal entities, services and promises of services between the corporation and persons who derive income from this corporation within the meaning of § 20 para 1 numbers 1 and 9 of the Income Tax Act, are to be treated for the purposes of implementing taxation with income taxes like services and promises of services between a legal entity and its shareholders.

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