Germany's Ministry of Finance has issued guidance in relation to the 20 September 2018 decision of the Court of Justice of the European Union (CJEU), which found that Germany's participation exemption conditions for trade (business) tax purposes constitute a restriction on the free movement of capital because stricter conditions are applied in relation to dividends paid by subsidiaries established in third countries outside the EU ({News-2018-09-26/A/3-previous coverage}). The guidance provides that as a result of the decision, the conditions for the participation exemption for trade tax purposes in relation to third countries are relaxed. This includes that the 15% shareholding...