It is pointed out that the Tax Authority bears the burden of proof that the CFC established in an EU/EEA member country does not carry out a substantial economic activity, which is supported by staff, equipment, assets and premises.
On the contrary, the tax authority does not have this burden if the CFC, as defined, is a resident a of a third country or, in case that the CFC has a permanent establishment is established in a third country, which is not a contracting party part of the EEA Agreement. In this case, the provisions of the CFC apply even if the CFC carries out a substantial economic activity.
The relevant provisions do not include a substantial economic activity test other than mentioned above.

As mentioned above (question 4) companies of which the main class of shares of which are traded on a regulated market are excluded (i.e. listed companies are excluded).