CFC rules apply if the CFC’s income arises from non-genuine arrangements that have been put in place with the essential purpose of obtaining a tax advantage (as provided in Article 7(2)(b) of the ATAD).
At the same time, this provision does not apply to CFCs whose accounting profits do not exceed EUR 750,000 and whose non-trading income does not exceed EUR 75,000, and which are not established in low-tax or tax-free jurisdictions as defined in national legislation.
Therefore, we do not assess the actual corporate tax paid by the CFC on its profits, nor do we track the income by specific categories.

In other words, under our law implementing ATAD CFC regulation a taxpayer shall include in their taxable base the part of the CFC profits (increase in asset value) which has been obtained from non-genuine arrangements of CFC`s. To avoid any double taxation, the taxpayer is entitled to adjust its tax base in amount of received dividends from CFC`s which was prior included.