On 20 April 2009, the State Secretary of Finance published a Decree, no. IFZ2009/234M, to amend the Decree on the avoidance of double taxation 2001 to combat group structures aimed at increasing creditable foreign withholding tax on interest. In 2008, the State Secretary of Finance was questioned about schemes by which investment funds increased the amount of foreign tax credit available by allocating expenses related to foreign source dividends, interest or royalties, e.g. interest to borrow funds for on-lending to related companies or related individuals within the meaning of Art. 10a CIT. The Decree provides measures against such schemes. If...