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related parties

  • The taxpayer and the person in which the taxpayer has direct or indirect majority control according to the to the provisions of the Civil Code, 
  • the taxpayer and the person that has direct or indirect majority control in the taxpayer according to the provisions of the Civil Code, 
  • the taxpayer and another person if a third person has direct or indirect majority control in both the taxpayer and such other person according to the provisions of the Civil Code, where any close relative holding majority control in the taxpayer and the other person shall be recognized as third parties, 
  • the foreign entrepreneur and its domestic place of business and the business establishments of the foreign entrepreneur, furthermore, the domestic place of business of a foreign entrepreneur and the person who maintains the relationship defined in points 1-3 above with the foreign entrepreneur, 
  • the taxpayer and its foreign branch and the taxpayer's foreign branch and the person who maintains the relationship defined in points 1-3 above with the taxpayer,
  • the taxpayer and another person if decisive influence is exercised between them with regard to identical management and the business and financial policy.

Two enitites may quailfy as related parties for the purpose of controlled foreign company (CFC) and capital decrease (divestment/divestiture) rules, if

  • the taxpayer and others person directly or inderectly own at least 25% of share of votes  
  • the taxpayer and others person directly or inderectly own at least 25% of capital share
  • the taxpayer and others person directly or inderectly own at least 25% of profitshare

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