Definition of CFC:If the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity (Art. 7 paragraph 1 ATAD); and the actual corporate tax paid on its profits by the entity or permanent establishment does not surpass 12.5%.