§ 12 para 4 was repealed in 2021. At the same time, the following changes were introduced:

§ 34 para 3c KStG
§ 8 para 1 in the version of Article 3 of the Act of June 25, 2021 (Federal Law Gazette I p. 2056) is also to be applied to assessment periods before 2021

§ 34 para 6d KStG
§ 12 para 4 in the version applicable on June 30, 2021, is to be applied for the last time for the assessment period 2020.

§ 8 para 1 sentence 4 KStG
For corporations as defined in § 1 para 1 with headquarters abroad, whose place of management is located domestically and which are not to be treated as legal persons under domestic corporate law due to lack of legal capacity, services and promises of services between the corporation and persons who earn income as defined in § 20 para 1 number 1 and 9 of the Income Tax Act from this corporation, are to be treated for the purposes of implementing taxation with income taxes like services and promises of services between a legal corporation and its shareholders.