Worldwide Tax Guide 2025/26

Key Tax Points

• All businesses irrespective of the legal status of the entity or company are subject to 20% corporate income tax on income under Article 4 of the Income Tax law in Afghanistan.
• Capital gains from the sale, exchange, or transfer of certain assets are treated as taxable Capital gains include the sale of a trade or business (including goodwill), a factory (including equipment, machinery, buildings and land, or any part of such assets), equipment used in the business of transporting persons and property, and shares of stock in corporations or limited liability companies.
• The calculation of tax on the taxable profits of branch offices of non-resident companies is the same as for other The tax is calculated at 20% of income after allowing certain deductible expenses.
• Individuals are subject to tax at progressive The monthly maximum limit is 20% + AFN 8,900 fixed amount.
• Any income tax paid to the government of a foreign country may be taken as a credit according to the principle of reciprocity.

Key Tax Points

• With effect from 1 January 2024, the standard rate of corporate income tax is levied at a rate of 15%. Before 2024, taxpayers with an annual turnover of up to ALL 14 million were subject to profit tax at a rate of 0%. The rate was 15% for taxpayers whose turnover exceeded ALL 14 For some small businesses, a 0% corporate income rate applies until 31 December 2029.
• The standard VAT rate is 20%. Reduced rates of 6% and 10% apply to certain
• Dividends and profit shares of partnerships paid to non-resident companies are subject to an 8% final withholding tax rate, subject to the application of a double tax treaty.
• Interest, royalties, technical service fees, management fees, insurance fees, payments for financial services, payments for construction, installation, assembly or related supervisory work, rental payments, and remunerations for performance of entertainment activities paid to non-resident companies are subject to a 15% final withholding tax rate, subject to the application of a double tax treaty.

Key Tax Points

• All companies are liable for corporate income tax on their profits arising from any business they carry on in Algeria, except for certain restricted categories mentioned in the tax code.
• All economic activities conducted in Algeria, including sales operations, imports, construction works and services, which are of an industrial, commercial or handicraft nature made in Algeria on a regular or occasional base are subject to VAT.
• Dividend withholding tax at a rate of 15% is imposed on dividends paid from Algerian sources to individual residents or non- resident individuals and legal entities, subject to the application of a double tax treaty.
• Relief from foreign taxes in Algeria depends on whether the country in question has entered into a double tax treaty with Algeria.

• Withholding tax applies to interests, dividends, royalties and technical service

Key Tax Points

• Income obtained by corporate entities established in Angola is subject to three different taxes: (i) Industrial Tax, which is levied on the corporate taxable income, including capital gains on the sale of fixed assets; (ii) Investment Income Tax, applicable to capital gains on the sale of securities, royalties, interest and dividend income; and (iii) Rental Income Tax, on rents collected from rented real estate as well as on deemed rented income from real estate owned by companies.
• The standard CIT rate is 25%. This rate also applies to non-residents with a permanent establishment in Different rates may apply to certain sectors like mining and Oil & Gas.

• VAT is levied on domestic supplies of goods, services and imports at a rate of 14%, although certain specified products and services are exempt from tax.

• Special tax regimes are in place for oil and mining
• Dividends paid to non-resident corporate shareholders are subject to a 10% investment income withholding tax on the gross dividends;

• Interest payments to non-resident companies are subject to a 15% investment income withholding tax on the gross amount paid.

• Royalty payments to non-residents are subject to a 10% investment income final withholding tax on the gross
• Services paid to non-resident entities are subject to a 5% withholding tax rate, which is a final withholding tax.
• Repatriation of profits attributable to a PE of a non-resident is subject to a 10% investment income withholding tax on the gross amount.

Key Tax Points

• Corporate income tax is levied at 25% on resident companies and branches held by non-resident
• Capital gains are generally not If capital gains occur regularly and frequently, they are considered income from trade or business.

• The standard rate of Antigua and Barbuda sales tax (ABST) is 17% (similar to VAT) effective 1 January
• There is no withholding tax on payments to resident companies. Interest, royalties, rentals, technical services fees and management fees paid by a resident company to a non-resident company are subject to a 25% final withholding tax unless a tax treaty applies.

Key Tax Points

• Companies domiciled in Argentina are subject to income tax on their worldwide Non-resident companies are subject to tax on Argentina-sourced income.
• There is no separate capital gains tax levied on capital gains of companies as they fall under the scope of corporate income
• VAT is applied at all stages of the production and selling processes (output tax). Tax suffered in the immediately preceding stage is deductible (input tax).
• Any foreign taxes paid on foreign-accrued income may be credited against Argentine income tax up to the limit of the Argentine tax on the same income.
• Transactions between Argentine companies and related parties are deemed to take place at arm’s length rates for tax purposes. For income tax assessment purposes, Argentine Law provides for the traditional methods generally used for transfer pricing (comparable uncontrolled price, resale price, cost plus, profit split, transaction net margin) to demonstrate that an arm’s length price has been used.
• Argentine-sourced income paid to foreign recipients not having a permanent establishment in Argentina is subject to 35% withholding tax. However, for each activity, the law establishes a percentage of presumptive net income on which 35% withholding tax is applicable, thereby reducing the effective tax rate.
• Income tax is levied on income earned by resident individuals in Argentina and
• Personal assets tax (wealth tax) is levied on all assets, wherever situated, of Argentine domiciled persons, on Argentine assets of non-domiciled persons and on shares issued by an Argentine company (the company pays the tax on behalf of the shareholders). In the case of trusts (excluding financial trusts), the trustee pays the tax on behalf of the beneficiaries.

Key Tax Points

General and specific taxation systems are applicable in Armenia.

Under the general taxation system, organisations, individual entrepreneurs and notaries are subject to VAT and/or profit tax and to patent tax regarding activities considered to be patent taxable objects.

Specific taxation system

• Companies are subject to turnover tax in lieu of VAT and/or profit tax while individual entrepreneurs and notaries are subject to profit tax and turnover tax in lieu of VAT, except for activities considered to be patent taxable objects;
• Under the patent tax regarding activities considered to be patent taxable objects, companies are subject to patent tax in lieu of VAT and/or profit tax while individual entrepreneurs are subject to profit tax and patent tax in lieu of VAT;
• Under the framework of family entrepreneurship, companies and individual entrepreneurs are exempt, in particular, from VAT and/or profit tax, as well as from turnover tax, except for types of activities considered to be patent taxable objects.

Key Tax Points

• Australian resident companies are subject to company income tax on income derived from all Non-resident companies are required to pay income tax only on Australian-sourced income.
• There is no branch profits tax in However, Australian branches of foreign companies will generally only be taxed on Australian-sourced income at the prevailing company tax rate.

• All entities that carry on an enterprise in Australia are required to register for the goods and services tax (GST) if their annual turnover meets the registration turnover threshold.
• Australia has a CFC regime which is designed to ensure certain types of passive and associated party income of a CFC is included in the controlling Australian resident’s taxable income each financial year.

• Where foreign sourced income is included in assessable income, tax credits are available equal to the lesser of the foreign tax paid and the Australian tax Credits are also available to Australian companies for foreign tax paid under the CFC regime on attributed income.
• Wholly-owned groups of Australian companies and, in some circumstances, unit trusts can elect to have their income tax liability calculated on a consolidated basis.
• Non-arm’s-length international profit-shifting arrangements and other international transactions between related parties are governed by transfer pricing rules which give the Commissioner of Taxation the power to calculate the income tax payable based on arms-length prices.
• Withholding tax must be deducted from interest, royalties and dividends (to the extent they are not franked) and certain other payments paid to non-residents.

• Income tax is payable by Australian resident individuals on non-exempt income derived from worldwide Non-resident individuals are only required to pay tax on Australian-sourced income.
• There is no separate capital gains tax, but capital gains are included in taxable income. The tax treatment of capital gains and losses is generally the same for individuals and trustees as for companies, but there are some differences (e.g. Australian resident individuals and trustees, unlike companies, can claim a 50% discount of capital gains on assets held for more than one year). Small business CGT concessions may also reduce capital gains where certain conditions are met.
• There is no net wealth tax, real estate tax or inheritance or gift tax.

Key Tax Points

• The corporate income tax rate applicable to capital companies (e.g., stock corporations and limited liability companies) as well as certain other legal entities, such as cooperative purchasing societies and mutual insurance associations, has been set at 23% effective 1 January 2024.
• Resident companies, e. entities with either their statutory seat or their place of effective management in Austria, are subject to unlimited corporate tax liability on their worldwide income. In contrast, non-resident companies are subject to limited tax liability, being taxed only on Austrian-source income, such as income attributable to a domestic permanent establishment.
• There is no separate capital gains tax applicable to Capital gains and losses are generally treated as ordinary business income or expenses and are subject to the standard corporate income tax rate.

• The Austrian group taxation regime allows for offsetting profits and losses within a qualifying group of In certain circumstances, losses incurred by foreign group members may also be utilised, subject to specific restrictions.
• Value Added Tax (VAT) is levied on the supply of goods and services by entrepreneurs within the scope of their business in Austria, as well as on imports into the Austrian customs The standard VAT rate is 20%, with reduced rates of 10% and 13% applying to specific goods and services.
• Austria imposes a withholding tax of 5% on dividends, unless reduced under a relevant double tax treaty (DTT). Withholding tax also applies to royalties (20%) and interest from financial instruments and bank deposits (25%).
• Austrian resident individuals are subject to unlimited income tax liability on their worldwide income, including income from employment, self-employment, business activities, real estate, and capital investments.

• Non-resident individuals are only subject to tax on income sourced in A person is typically considered resident in Austria if they maintain a domicile or habitual abode in the country, including a stay of more than six months.

Key Tax Points

• The general corporate profit tax rate is 20%.
• Capital gains are treated as ordinary income and taxed at the corporate profit tax rate of 20%.
• The standard VAT rate is 18%.
• Operating losses may be carried forward for five years and offset against profits in future years without Such losses may not be carried back.

• Dividends paid by an Azerbaijani resident entity to a non-resident legal entity are generally subject to a 5% withholding tax (10% before 1 January 2024) unless a reduced rate is available under an applicable tax treaty.
• Interest paid by an Azerbaijani resident entity or a PE of a non-resident to a non-resident, including the interest component of a finance lease, is subject to a 10% withholding tax, unless a reduced rate is available under an applicable tax treaty.
• Royalties paid by an Azerbaijani entity to a non-resident are subject to a 14% withholding tax, unless a reduced rate is available under an applicable tax treaty.

• Payments made by an Azerbaijani resident to a non-resident for services performed within or outside of Azerbaijan are subject to a final withholding tax of 10%, except for payments for telecommunications and certain international transportation services, which are subject to a 6% rate as well as payments for transportation services between destination (shipping) points in other states outside Azerbaijan, as well as services reduced under an applicable tax treaty.
• Rent payments made by a resident entity to a non-resident are subject to a 14% withholding tax.

Key Tax Points

• Whilst there is still currently no personal income, capital gains, withholding, inheritance and estate taxes, the Government recently enacted the Domestic Minimum Top-Up Tax Act, 2024, targeted at multi-national corporate entities. Bahamian entities that are a part of multinational entities (MNEs) which meet specific pillar 2 requirements (e.g. revenues in excess of specified limits) will be liable for this tax. Essentially, where the effective tax rate (ETR) is below 15%, a top-up tax is levied. Whilst many domestic (locally owned) entities will not be affected by these thresholds, the implementation is aimed to ensure a minimum level of taxation for multinational entities, as prescribed by the Organisation for Economic Co-operation and Development (OECD).
• Income received in the Bahamas may be subject to tax in the country of
• There are some tax information exchange agreements between the Bahamas and other countries.

Key Tax Points

• No form of personal, corporate or withholding tax is applicable In There is no personal tax except for municipal tax of 10% on the monthly rental of residential and business property.
• A 5% VAT rate was implemented effective 1 January This was increased to 10% effective 1 January 2022.
• There is no withholding tax on dividends, interest, royalties and fees paid to non-residents.

Key Tax Points

• In Bangladesh, the principal taxes are Customs Duty, Value-Added-Tax (VAT), Supplementary Duty, Personal income tax and corporate income tax.

• According to the Finance Act 2023, VAT rates vary from 5% to 15% depending on the types & nature of VAT imposable goods & The previous 15% standard rate is also applicable if so desired by the VAT payers but in that case, no VAT credit for input tax will be allowed.
• For Bangladesh tax purposes, income is categorised into seven areas, namely, salaries, interest on securities, income from house property, agricultural income, income from business or profession, capital gains and income from other sources.

• Among direct taxes, income tax is one of the main sources of It is a progressive tax system. Income tax is imposed on the basis of ability to pay, based on the principle of “…the more a taxpayer earns, the more he should pay”. It aims at ensuring equity and social justice.
• The income tax rate for individuals, who are a resident assessee or non-resident Bangladeshi vary from 5% to 25% depending on the amount of total taxable income and for individuals who are a non-resident assessee (except non-resident Bangladeshi) the flat tax rate is 30%.
• For the 2024-2025 tax year (1 July 2024 to 30 June 2025) the top corporate tax rate is 45% + 5% surcharge for all cigarette manufacturing companies. Publicly traded companies registered in Bangladesh are taxed at a lower rate of 20% to 25% depending on transferring paid-up capital.
• An individual is treated as a resident of Bangladesh if that person stays in Bangladesh for 182 days or more in any income year; or 90 days or more in an income year if that person has previously resided in Bangladesh for a period of more than 365 days during the 4 preceding years. Residence is determined in Bangladesh purely on the period of presence in Bangladesh, irrespective of residency in other Short-term visitors and dependents of foreign nationals not earning any income in Bangladesh are not taxed and are not required to file a tax return in Bangladesh.
• In general, all remuneration and benefits received by an employee who is resident in Bangladesh, or for services rendered in Bangladesh, are taxable. Taxable remuneration and benefits include salary, bonuses, commissions, accommodation allowances, transport benefits, education allowances for children, employer-provided domestic assistance and medical allowances.

Key Tax Points

• A resident company is liable for Belgian resident corporate tax (CIT) on its worldwide profits (with Belgian tax relief for eligible foreign-source profit). A non-resident company, i.e. a legal branch or permanent establishment, is liable for Belgian non- resident corporate tax levied on Belgian-source income only.
• Capital gains are normally treated as ordinary business income and are taxable at the normal corporate tax rates, be it that tax exemptions and roll-over tax relief are available if certain conditions are met.

• Belgian tax law comprises controlled foreign company (CFC) legislation as of
• Belgian tax law comprises group relief for corporate tax purposes as of In addition and subject to certain conditions, separate taxable persons can form a VAT unit and hence be considered as a single taxable person for VAT purposes.
• The standard Belgian withholding tax rate applicable to dividend, interest or royalty income is 30%. However, both Belgian domestic tax law and double tax treaties concluded by Belgium comprise numerous withholding tax exemptions that can be claimed by various investors, mainly non-residents and financial institutions.
• An individual resident in Belgium is liable for progressive personal income tax rates that apply to worldwide Qualifying foreign-source income can be eligible for a Belgian personal tax exemption with progression reserve if conditions are met.
• Belgian tax law does not comprise asset tax nor a general capital gains taxation for
• Belgium had a very tax-attractive expatriate tax regime for foreign executives who are temporarily working in Belgium after being seconded to Belgium or being recruited outside However, as of 1 January 2024, tax concessions are no longer applicable to these expats as they are now considered Belgian tax residents, as opposed to the old favourable regime.
• Belgium has a very extensive tax treaty network and a very active tax treaty
• Belgium has a very active upfront tax ruling No-name pre-filing meetings with the Belgium tax ruling commission are common practice.
• Taxable persons performing supplies of goods or services have to charge 21% VAT on these supplies unless these transactions are subject to a reduced rate, ‘exempt’ from VAT, ‘outside the scope’ of VAT or subject to ‘reverse charge’.

Key Tax Points

• Income tax is levied on the gross revenue receipts (sales) of companies at rates set out from time to time in the Ninth Schedule to the Income and Business Tax Act.
• A general sales tax (GST) applies to the supply of goods and services at a standard rate of 12.5%. Certain supplies are exempted or zero-rated. Registered businesses can set off their input GST (GST paid to suppliers) against their output GST (GST charged to customers).
• Other local taxes apply including stamp duty, land and property taxes, customs duties, excise duties, environmental tax, vehicle licenses, and trade license.

• Personal income tax is chargeable at a flat rate of 25% on persons employed in
• Belize has double taxation agreements with Austria, Switzerland, the United Arab Emirates, the United Kingdom, and the countries of the Caribbean Community (CARICOM).

Key Tax Points

• The standard corporate income tax rate is 30%.
• VAT is levied at a standard rate of 18%.
• Losses may generally be carried forward for up to 5 Loss carry-back is not allowed.
• Dividends paid to non-resident companies are subject to a 5% final withholding tax on the gross amount (15% before 2022), subject to the application of a double tax treaty.
• Interest derived by a non-resident company is subject to a 15% final withholding tax on the gross amount, subject to the application of a double tax treaty. Reduced withholding tax rates are in place.
• Copyright royalties, patent royalties, and any other kinds of royalties, paid to non-resident companies are subject to a 12% final withholding tax rate on the gross amount, subject to the application of a double tax treaty.
• Remuneration for technical assistance and management fees paid by Benin resident companies to non-resident companies is subject, effective from 1 January 2023, to a final withholding tax at a rate of 20% of the gross payment (12% before that date).

Taxes Payable

Company Tax

The tax base in Bolivia is territorial, i.e. tax is only due on business income derived from activities performed, property situated,

or economic rights used in Bolivia, regardless of nationality, domicile or residence of those who take part in the operations. Therefore, business income realized through companies operating outside of Bolivia is not considered for Bolivian tax purposes.

The standard corporate income tax rate is 25% and the tax year-end is 31 December of each year. Annual tax returns and financial statements need to be submitted with the IRS and income tax paid within 120 days from tax year-end. Advance corporate tax payments need to be made.

Capital Gains Tax

Capital gains derived from the sale of fixed assets immovable property and securities are normally included in gross income and are subject to the standard corporate income tax rate of 25%. However, capital gains derived from transactions on the Bolivian Stock Exchange are tax-exempt.

Branch Profits Tax

Branches of non-resident companies are subject to the standard corporate income tax rate of 25%. However, a branch remittance tax applies at the rate of 25%, which is levied on 50% of the Bolivian-sourced profits distributed to the foreign head office, i.e. the effective rate is 12.5%. Branch profits are deemed remitted when the corporate income tax return is due (120 days after the end of the tax year, see higher).

Sales Tax / Value Added Tax (VAT)

VAT is levied on taxable supplies of goods and services as well as on imports of taxable goods and services into Bolivia. Exports are zero-rated. Some specified transactions are exempt without credit for previously paid VAT.

The standard VAT rate is 13% while certain goods and services are tax-exempt:

• bona fide imports made by travellers arriving to the country;
• all transactions of public offer securities registered with the Stock Exchange Register (RMV) performed in Bolivia and having effect in the national territory;
• cession of goods and assets subject to procedures for issuing securities;
• goods imported by diplomatic service members;
• transactions involving the transfer of financing intermediation, insurance, pensions and stock exchange portfolios, whether resulting from sale or cession;
• the importation of printed books, newspapers and

Transactions Tax

Transactions tax is a tax on gross income arising from the performance of any economic or commercial activity (including non- profitable activities) at a rate of 3% on a monthly basis. Some exceptions may apply on the sale of investments and the sale of minerals, oil, and gas within the local market, as long as such sales will ultimately be exported.

Corporate income tax paid at the end of a fiscal year may be offset against future transactions taxes to be paid in the subsequent fiscal year.

Tax On Specific Consumption

Applies to sales of specific goods on the domestic market and imports of goods for final consumption:

• Cigarettes and
• Refreshing
• Alcoholic
• Undenatured
• Motor

The payment varies depending on the good: percentage rates on the net sales price or specific rates on sales volumes are due expressed in litres or quantity expressed in units.

Financial Transactions Tax

A financial transactions tax is levied on bank transactions (deposit or transfer of funds), carried out within the domestic financial system, at a rate of 0.30% for fiscal years 2018 through 2023.

This tax is withheld by the relevant bank or financial institution. In addition, a corporate tax exemption is provided for creditors in relation to interest on public debt issued through securities in external capital markets.

Key Tax Points

• Corporate income tax is levied at a single rate of 22%.
• Branches of non-residents companies are subject to 30% corporate income
• The capital gains tax rate for companies is 22%, the same rate as the CIT
• VAT is imposed comprehensively on an end-user basis at the rate of 14% on standard rated supplies.

Key Tax Points

• Corporate income tax (CIT) is charged at a set rate of 15% plus a surcharge of 10% on profits over a set level, and there is also a social contribution tax on profits charged at a rate of 9% for legal entities in general or at 15% in case of legal entities considered to be financial institutions, private insurance and capitalization.
• Most companies with prior year revenue below a prescribed amount can, under certain circumstances, choose to pay income tax and social contributions calculated under the ‘presumed profit method’.

• Other federal taxes include fringe benefits tax, social security contributions (COFINS), social integration program contribution (PIS), payroll tax including employer social security contributions (INSS), value added tax on sales and transfers of products manufactured in or imported into Brazil (IPI), financial operations tax (IOF), and rural real estate tax (ITR).
• Municipal taxes include Services Tax (ISS or ISSQN), and estate transfer tax (ITBI) payable at a rate of up to 4% on inheritances and donations of properties and rights, and a services tax is imposed by many cities, with rates varying substantially between
• Profits and gains from foreign sources are taxable in Tax credits are available to relieve double taxation subject to a maximum of the Brazilian tax payable on the income.
• Dividends paid by a Brazilian company to a non-Brazilian shareholder are not subject to Brazilian withholding tax (IRRF).
• Interest, including interest on net equity paid to shareholders paid by resident companies to non-resident companies is subject to withholding tax at a rate of 15% in Brazil, unless the beneficiary is resident in a tax haven jurisdiction, in which case a 25% rate applies, subject to the provisions of an applicable double tax treaty.
• Withholding tax is levied on any amounts of royalties paid, remitted, credited, used in favour of and delivered by a Brazilian paying source to abroad at the rate of 15% unless the recipient is a resident in a tax haven jurisdiction, in which case a 25% rate applies.
• Taxes payable by individuals include personal income tax, social security tax and gift and inheritance
• Brazilian resident individuals are taxable on their worldwide earnings, as well as gains on the disposal of worldwide assets and rights.

• Personal income tax is withheld at source (at progressive rates from 5% to 27.5%).
• Capital gains arising other than out of financial instruments are subject to income tax at 15%. As from 2019 tax rates applicable to capital gains are as follows:
  • 15% up to BRL 5 million;
  • 5% from BRL 5 million to BRL 10 million;
  • 20% from BRL 10 million To BRL 30 million;
  • 5% over BRL 30 million.

Key Tax Points

• There is no corporate income tax, no capital gains tax, no branch profits tax and no VAT in the British Virgin Islands (BVI).
• Customs duties are levied on most goods imported into the BVI at ad valorem rates, expressed as a percentage of the value of the goods. These rates range from 5% to 20%.
• There is no withholding tax on interest, dividends or royalties paid by BVI
• Payroll tax is charged on every employer who carries on business on the BVI. An employer must pay to the BVI Tax Authority 14% of the employee’s remuneration over and above USD 10,000 per calendar year, split between the employee and employer at a rate of 8% for the employee (as a deduction from the employee salary) and 6% for the employer.

Key Tax Points

• Income tax in Brunei is governed by the Income Tax Act (Chapter 35) and Income Tax (Petroleum) Act (Chapter 119), Laws of
• Resident and non-resident companies are liable for corporate income tax on income accrued in, derived from or received in Brunei from outside Brunei.
• Companies with Gross Sales or Turnover that does not exceed BND 1 million are exempted from corporate tax or taxed at a zero rate. Audited financial statements are also exempted if none of the shares are held by corporate shareholders.
• The period of assessment is on a preceding year Year of assessment is based on a calendar year ending 31 December.
• Dividends received from a corporation taxable in Brunei are exempt from
• There is no capital gains tax in
• There is no goods and services tax in
• Tax exemption is available for pioneer industry companies between 5 to 20 years, depending on certain criteria being
• There are various tax exemptions and incentives to encourage trading and investment in
• Up to a certain amount, chargeable income (CI) of new companies is tax-exempt for the first 3 tax years of There are also exemptions on 75% of the first BND 100,000 of CI and on 50% of the next BND 150,000 of CI.
• Transactions involving related resident and non-resident entities must be conducted on an arm’s length There are no thin capitalisation or controlled foreign company (CFC) provisions.
• Dividends are not subject to withholding tax in Interest, royalty and certain other payments by Bruneian companies to non-resident companies are, however, subject to withholding tax.

• There is no personal income tax in Brunei.

Key Tax Points

• Corporate Income tax in Bulgaria is a 10% flat rate on the taxable
• The standard VAT rate is 20%. There is a reduced rate of 9% for hotel accommodation services, supplies of books and periodicals in physical or online form, supplies of food suitable for babies or young children and baby hygiene articles, restaurant and catering services, general tourist service supplies, supply of service for use of sports facilities, supply of central heating, supply of natural gas, and 0% for supply of bread and flour.
• Withholding tax is due on dividends, interest, royalties and various other types of income, when distributed to a non-resident
• Bulgarian tax residents are taxed on their worldwide Non-residents are taxed only on their Bulgarian-sourced income.
• An inheritance received by the surviving spouse, children and their descendants is Various rates of inheritance tax apply to other relatives.

Key Tax Points

• The standard corporate income tax rate is 5%.
• A branch profits tax is levied at the rate of 5% on a taxable base of 75% of profits realized in Burkina Faso, resulting in an effective rate of 9.375%.
• VAT is levied at a standard rate of 18%.
• Losses may generally be carried forward for up to 5 Loss carry-back is not allowed.
• Dividends paid to non-resident companies are subject to a 5% final withholding tax on the gross amount. This rate is reduced to 6.25% for newly incorporated companies during the first 3 years of activity and for mining companies.
• Interest derived by a non-resident company is subject to a standard 25% final withholding tax on the gross Reduced rates may also apply.

• Royalties and payments for services (including technical and management fees) paid to non-resident companies are subject to a 20% final withholding tax rate on the gross amount.

Key Tax Points

On 16 May 2023, the new Law on Taxation (“LOT”) was promulgated by Royal Kram No. NS/RKM/0523/004.

• General overview

Most business activities and investments in Cambodia will be affected by the following taxes:

• Corporate income tax/Tax on income
• Minimum tax
• Withholding tax
• Value added tax
• Tax on salary of employees
• Fringe benefit tax

There are various other taxes that may affect certain activities in specific industries, including:

• Specific tax on certain merchandise and services (excise tax)
• Custom duty
• Public lighting tax
• Other taxes

• Cambodian tax system

Cambodia’s tax system is a self-declaration regime. The estimated and simplified regimes were eliminated in 2016, and the term ‘real regime’ has been replaced by the term ‘self-declaration regime’. Taxpayers under the self-declaration regime are classified into three categories:

1. Small taxpayer is any sole proprietorship or partnership that has:
   • annual turnover from KHR 250 million to KHR 1,000 million (approximately USD 62,500 to USD 250,000) for agricultural, service, and commercial sectors; or

• annual turnover from KHR 250 million to KHR 1,600 million (approximately USD 62,500 to USD 400,000) for the industrial sector; and

• turnover of at least KHR 60 million (approximately USD 15,000) for any three months ending in the current fiscal year; and

• expected turnover for the next three-month period to be at least KHR 60 million (approximately USD 15,000); and
• participate in any bidding or quotation for the supply of goods or services, including market stall

2. Medium taxpayer includes any sole proprietorship or partnership that has:
   • annual turnover from over KHR 1 billion to KHR 4 billion (approximately USD 250,000 to USD 1,000,000) for the agricultural sector, or

• annual turnover from over KHR 1 billion to KHR 6 billion (approximately USD 250,000 to USD 1,500,000) for service and commercial sectors; or
• turnover from over KHR 6 billion to KHR 8 billion (approximately USD 250,000 to USD 2,000,000) for the industrial sector.

A medium taxpayer also includes:

• enterprises that have been incorporated as a legal entity, representative office; or
• national and subnational government institutions, all types of organizations or associations, including non- governmental organizations; or
• foreign consulates and embassies, international organizations, and technical cooperation agencies of other

3. Large taxpayer includes any sole proprietorship, partnership, or legal entity that has:
   • annual turnover exceeding KHR 4 billion (approximately USD 1 million) for the agricultural sector; or
   • annual turnover exceeding KHR 6 billion (approximately USD 5 million) for service and commercial sectors; or annual turnover exceeding KHR 8 billion (approximately USD 2 million) for the industrial sector.

A large taxpayer also includes:

• Branches of foreign companies;
• subsidiaries of multinational companies;
• Enterprises registered as Qualified Investment Projects (“QIPs”) approved by the Council for the Development of Cambodia.

Under Prakas 009 the GDT now has the authority to re-determine the classification of a taxpayer if the declared turnover does not reflect actual turnover. In this circumstance, a taxpayer will be classified using the value of their assets (current and non- current) as follows:

1. Small taxpayer is any sole proprietorship or partnership that has:
   • assets valued at KHR 200 million to KHR 1,000 million (approximately USD 50,000 to USD 250,000) for agricultural, service, and commercial sectors; or

• assets valued at KHR 200 million to KHR 2,000 million (approximately USD 62,500 to USD 500,000) for the industrial sector.

2. Medium taxpayer includes any sole proprietorship, partnership, or legal entity that has:
   • assets valued at KHR 1 billion to KHR 2 billion (approximately USD 250,000 to USD 500,000) for agricultural, services, and commercial sectors, or

• assets valued at KHR 2 billion to KHR 4 billion (approximately USD 500,000 to USD 1,000,000) for the industrial

3. Large taxpayer includes any sole proprietorship, partnership, or legal entity that has:
   • assets valued above KHR 2 billion (approximately USD 500,000) for agricultural, services, and commercial sectors; or
   • assets valued above KHR 4 billion (approximately USD 1 million) for the industrial

Anyone falling within one of the above categories is required to begin the tax registration process within 15 working days of commencing business activities or incorporating. One of the main hurdles in registering for tax is the General Department of Taxation’s (“GDT”) requirement that one of the principals of the entity appear in person at the GDT at the time of registration.

A taxpayer’s classification will determine the amount of patent tax that must be paid. Additionally, small taxpayers have fewer requirements when it comes to record-keeping. Small taxpayers are permitted to use a simplified accounting system, whereas medium and large taxpayers are expected to keep proper accounting records and books in line with Cambodian Accounting Standards.

Currently, Cambodia does not have a comprehensive personal income tax system that requires individuals to file and pay taxes to the GDT directly.

• Tax service agents

On 12 April 2013, Prakas on Tax Service Agents No. 455 SHV.PrK was issued requiring that those who offer tax services for entities other than their employer must be licensed as a tax service agent (“TSA”). With the GDT’s issuance of Notification No. 20869 GDT on 31 August 2022 advising that TSA licenses had been issued to 245 companies, this requirement is now being enforced.

For taxpayers, this means that they may continue to file their own monthly and annual returns and represent themselves at the GDT. However, if they hire outside tax service assistance, a licensed TSA must be engaged, and they must provide a written power of attorney for the TSA to act as their tax representative.

As of 1 January 2017, and further to the Prakas no. 230 dated 23 March 2022 issued by the Ministry of Economy and Finance (‘’MEF’’), individuals or companies that do not have a TSA license are not allowed to provide tax services, or act as a taxpayer representative. Those found to breach this provision will be penalized and taxpayers who engage unlicensed TSAs will be subject to a fine of KHR 5 million to KHR 10 million or imprisonment from 1 (one) month to 1 (one) year or both.

• Tax Audits

Taxpayers may be subject to tax audits at the discretion of the GDT. These may be conducted up to 10 years after the initial filing of a tax return.

There are three kinds of tax audits:

1. Desk audit: This level of control is designed to verify the accuracy of declared information by cross-checking it with the tax return or other information requested by the tax administration.
2. Limited tax audit: This audit is more The tax auditors will use all available resources, including visits to the taxpayer’s place of business, to verify the accuracy of the taxpayer’s returns.

3. Comprehensive tax audit: In practice, this is the same as a limited audit, only more The important distinction between a comprehensive audit and a limited audit is that once the audit has been completed, and any resulting tax reassessments have been paid, all tax years covered by the audit will be closed.

Although a comprehensive tax audit is normally final, if the tax administration has reason to believe a taxpayer has committed tax evasion or fraud, they may re-open the case. Taxpayers achieving Gold or Silver Compliance Status are exempt from desk audits and may be subject to other audits on a less frequent basis. There will be generally only one “site audit” within 3 years. It may be the case that a joined tax audit (between limited and comprehensive tax audit) is conducted as one ‘site audit’’.

However, the tax administration may conduct a tax audit anytime if risk or abnormality is found.

Key Tax Points

• The regular corporate income tax rate is 30%, plus a 10% additional council tax, resulting in an effective corporate tax rate of 33%. However, for medium-sized companies with a turnover of less than or equal to XAF 3 billion the income tax rate is reduced to 25%, plus a 10% council tax surcharge, resulting in an effective corporate tax rate of 27.5%.
• The effective standard VAT rate is 25% (a 17.5% VAT and 10% council tax surcharge).
• Subject to the application of a double tax treaty, a non-resident company is subject to income tax on dividends at a flat rate of 15%, which must be withheld by the resident paying company. A 10% council tax surcharge is added, resulting in an effective rate of 16.5%.
• Subject to the application of a double tax treaty, interest payments made by a resident company to a non-resident company are generally subject to a 15% withholding tax, plus a 10% council tax surcharge, resulting in an effective rate of 16.5%.
• Subject to the application of a double tax treaty, royalties paid to non-resident persons by resident companies are subject to a Special Income Tax (SIT), withheld at source, at rates from 3% to 15%, depending on the nature of the royalty paid.
• Subject to the application of a double tax treaty, remuneration paid to non-resident persons by resident companies for various services (including technical and digital services) in Cameroon are subject to a Special Income Tax (SIT), withheld at source, at rates from 3% to 15%, depending on the nature of the services.

Key Tax Points

• Companies pay federal, provincial, and municipal The combined federal and provincial or territorial corporate tax rates vary depending upon the province or territory where a corporation conducts business and the nature of its operations.

• A special 25% ‘branch tax’ applies to a non-resident’s after-tax profits that are not invested in qualifying property in Canada. The branch tax essentially is equivalent to a non-resident WHT on funds repatriated to the foreign head The rate of tax is subject to reduction when there is a tax treaty between Canada and the corporation’s country of residence.

The federal government imposes a Goods and Services Tax (GST) of 5% on a wide range of goods and services. (5% GST in Alberta, British Columbia, Manitoba, Northwest Territories, Nunavut, Quebec, Saskatchewan, and Yukon.) Exemptions are provided for certain products. Examples of zero-rated supplies include basic groceries, medical and assistive devices, prescription drugs, feminine hygiene products, agriculture and fishing, and most international freight and passenger transportation services etc.

Also zero-rated goods and services are taxable at a 0% rate. However, in ON, the HST (harmonised sales tax) rate is 13%. In New Brunswick, Newfoundland and Labrador, Nova Scotia (government proposes to decrease the province’s HST rate to 14% from April 2025), and Prince Edward Island, the HST rate is 15%.

• No provision is made for filing consolidated tax returns for corporate However, loss utilisation among members of a corporate group is often implemented by amalgamation or merger of group members.
• Non-resident withholding tax applies to many types of income paid or credited to non-residents including dividends, interest, royalties, pension payments and rents. The statutory rate of withholding is 25% but this may be reduced or eliminated by treaty provisions.
• Canadian Residents are subject to tax on their worldwide income. Non-residents are subject to tax in Canada on Canadian- sourced employment income and business income only. However, if Canada and the country of residence of the taxpayer have concluded a tax treaty, then the tax rate might be reduced; 50% of the capital gain from the disposal of certain Canadian assets and 100% of the capital gain on disposal of certain property such as resource property or certain life insurance policies.

Key Tax Points

• Resident corporations are subject to Cape Verde corporate income tax (CIT) on their worldwide income. Non-resident companies with a permanent establishment in Cape Verde are liable for CIT on the income attributable to that permanent
• There is a CIT simplified regime for micro and small-sized companies in
• A tax-neutral regime for mergers and spin-offs is available, subject to certain
• Transfer pricing legislation enables the tax authorities to make corrections to taxable income when the conditions (and prices) agreed upon between related parties are different from those that would have been agreed upon and accepted between independent entities (arm’s-length principle). In certain cases, transfer pricing documentation is required.
• Companies licensed in the International Business Centre of Cape Verde are taxed at a reduced CIT
• Payments between resident companies are generally subject to withholding
• The standard rate of VAT is 15%.
• Resident individuals are subject to income tax on their worldwide income whilst non-residents are liable to income tax only on income sourced in Cape Verde. There is a special tax regime for non-habitual resident taxpayers.
• Social security is due on remunerations at a 16% rate for the employer and 5% for the employee.

Key Tax Points

• Effective 1 January 2024, corporate income tax is charged at a standard rate of 30% (previously 35%) on income over FCFA 20,000.

• VAT is levied at a standard rate of 18%.
• Losses may generally be carried forward for up to 3 Loss carry-back is not allowed.
• Dividends paid to non-resident companies are subject to a 20% final withholding tax on the gross amount. Dividends derived by CEMAC (Central African Economic and Monetary Community) resident companies are subject to a 10% reduced withholding tax. Where the CEMAC recipient’s shareholding is at least 25%, the dividends are subject to a 5% final withholding tax.
• Effective 1 January 2024, interest derived by a non-resident company is subject to a 18% (previously: 25%) final withholding tax on the gross amount. The rate is reduced to 5% for interest derived by CEMAC residents.
• Royalties paid to non-resident companies are subject to a 25% final withholding tax rate on the gross A 7.5% non-final withholding tax applies to royalties derived by CEMAC residents.
• Effective 1 January 2024, technical, financial and accounting assistance, interconnection usage charges for a mobile network, as well as medical service fees, paid by companies resident in Chad to non-resident recipients are subject to a 18% (previously: 25%) final withholding tax. A 7.5% non-final withholding tax applies to recipients who are resident in a CEMAC member country. A 0% withholding tax applies where the recipient is resident in a CEMAC member country and carries out non- commercial activities.

Key Tax Points

• The Chilean income tax system applies to all individuals and entities domiciled or resident in Chile in respect of their worldwide income. Non-residents are subject to tax on Chilean-sourced income.
• Two categories of income tax apply in relation to different types of income (activities). The rules for calculating tax under each category are different.
• In general, profits from commercial activities (including relevant capital gains) are taxed at 25% under ‘First Category tax’.
• However, as of 2020 the general tax system (Partially integrated system) affects profits made by enterprises that determine the income tax taking into account the results of financial statements based on full accounting records, at a rate of 27%. Such system has a maximum tax burden of 44.45%, taking into account both the tax on the company (First Category tax at 27%) and the owners (Additional tax at a rate of 35% or Global Complementary tax with progressive tax rates). Under the Partially integrated system the higher burden results from the owners having to refund 35% of corporate tax (First Category Tax) on the same taxable profit distributed or withdrawn. However, the restriction in the use of corporate tax as a credit will not be applicable to investors domiciled or resident in countries that have a double tax treaty with Chile, in which the application of the Additional Tax on the income distributed or withdrawn has been agreed upon provided that the First Category Tax is deductible of said tax, or another clause is included producing the same effect.

• Gross taxable income arising from wages, salaries, overtime payments, bonuses, fees, gratuities, profit sharing and any other form of remuneration is taxed under the Second Category which is a progressive tax, the highest rate of which is 40% from 2020 onwards.
• Profits remitted or withdrawn from Chile (such as by way of payment of dividends to non-residents in enterprises subject to the Partially Integrated System) are subject to a 35% ‘Additional Tax’, although relief is given for any First Category tax paid on the relevant profits. Some of the taxpayers domiciled or resident abroad may have to refund the 35% of the tax credit, which means that in practice they could only use the 65% of the First Category tax as a tax This restriction is applicable only to taxable income generated since 1 January 2017.
• Transfers and other operations regarded as sales, as well as services other than those rendered by employees and consultants, are subject to 19% Value Added Tax (VAT). Exports of all products and services qualified as exports by the Customs Service are exempt for VAT purposes (0% rate). VAT paid on imports and on local purchases and services may be deducted from VAT surcharged on sales or services rendered.

• There are various other types of payments to non-residents which are subject to withholding Chile has signed double tax treaties with a number of countries under which the withholding tax rate may be reduced or the tax may not be applicable.

• Credits are available for overseas taxes paid on foreign-sourced Where the income consists of dividends or overseas profits, the credit is capped at a maximum of 35% of the gross dividends or profits.

• Although individuals resident in Chile generally pay income tax on their worldwide income, foreigners who establish their domicile or residence in Chile pay income tax only on their Chilean-sourced income for the first three years of residence.

Key Tax Points

• Corporate residents of China are taxed on their worldwide income. A foreign tax credit is allowed for income taxes paid in other This credit is capped at the China income tax payable on the same income calculated under the Enterprise Income Tax Law.
• The Enterprise Income Tax Law unified the rate for domestic and foreign enterprises at 25% from 1 January For small profit making companies, the rate could be reduced to 20%. Since 2010, the government authorities have issued favourite policies to promote the business of small profit making companies.
• Foreign enterprises with establishments in China deriving the above income which is not effectively connected with that establishment is also subject to withholding The statutory rate is 20% which is reduced to 10% by the Enterprise Income Tax Law Implementation Regulations. The 10% withholding tax may be reduced under an applicable treaty.
• Foreign enterprises without establishments in China are subject to Enterprise Income Tax on a withholding basis on the income of dividends, royalties, interest, rental income, earnings from assignment of assets in China and any other income derived from inside China.
• Individuals are taxed on the comprehensive income and business income at progressive
• There is no separate tax on capital Capital gains will be considered as general taxable income and thus subject to Enterprise Income Tax or Individual Income Tax.

• Turnover taxes include VAT on all goods and services and Consumption Tax on consumable or luxury
• Land Value Appreciation Tax applies to transfers of land use rights and immovable
• Stamp duty is levied on a variety of contracts and certain legal documents.

Key Tax Points

• The current standard corporate income tax rate applicable to Colombian and foreign companies is 35%.
• The standard VAT rate is 19%. Reduced rates of 5% and 0% are also in
• Losses sustained by a company in a tax year can be carried forward and deducted during the following 12 tax No carry- back of losses is allowed.

• The withholding tax requirements for dividends paid by domestic corporations to non-resident corporations depend on whether the dividends are paid from taxed profits, or from untaxed profits:
• As a general rule, interest paid on foreign loans by a Colombian resident is Colombian-sourced income and is subject to Colombian income tax The standard rate is 20%. However, interest payments are subject to withholding at a rate of 15% if the loan is granted for a term equal to or exceeding one year.
• Taxable royalties paid to a non-resident are subject to a withholding tax of 20%.

Key Tax Points

• The standard corporate income tax rate is 28%.
• VAT is levied at a standard rate of 18%.
• Losses may generally be carried forward for up to 3 Loss carry-back is not allowed.
• Dividends paid to non-resident companies are subject to a 15% final withholding tax on the gross amount, subject to the application of a double tax treaty.
• Interest derived by a non-resident company is subject to a 20% final withholding tax on the gross amount, subject to the application of a double tax treaty. Reduced rates are also in place.
• Royalties paid to non-resident companies are subject to a 10% final withholding tax rate on the gross amount, subject to the application of a double tax treaty.
• Technical fees and management fees paid to non-resident companies are subject to a 20% final withholding tax rate on the gross amount.

• The Finance Law 2023 introduced, effective 1 January 2023, a 10% withholding tax on sums paid by a Congolese resident to a resident of any other CEMAC member country for services rendered.

Key Tax Points

• A resident company pays a flat 20% corporate income tax on worldwide profits while a non-resident company pays 28% corporate tax on profits derived from Cook Islands-sourced income.
• VAT is levied at 15% on most goods and
• Dividends, interest, royalties, and technical/management fees paid to non-resident companies are subject to a 15% withholding tax.

Key Tax Points

• In 2025, corporations with gross annual income over CRC 119,629,000 (CRC 120,582,000 in 2024) are taxed at the standard rate of 30% (unchanged from 2024).
• Costa Rica’s general VAT rate is 13%. However, there is a 4% tax on airline tickets and healthcare services while a 2% tax is levied on medical products, raw materials and machinery used for production, insurance premiums, purchase and sale of university issued products. Basic food necessities from a specific list are subject to a 1% tax.
• Dividends paid to individuals or foreign entities are subject to a 15% final withholding tax. A lower rate of 5% applies if the stock of the company distributing dividends is traded on the Stock Exchange and if such stock was acquired on that
• Interest, commission, fees and other financial expenses paid or credited to non-residents are subject to a 15% final withholding tax applied to the gross amounts, subject to certain exemptions.
• Royalties from a Costa Rican-source paid or credited to non-residents are subject to a 25% final withholding tax on the gross amount.

• Technical and financial advice fees are subject to a 25% final withholding tax on the gross amount.

Key Tax Points

• Companies resident in Croatia are subject to corporate tax on profit generated domestically and Non-resident companies are subject to corporate tax only on profit generated domestically.
• There are no specific rules for branches or groups of Each company is taxed separately.
• Transactions between related companies have to respect transfer pricing
• The standard VAT rate is 25%. There are also reduced rates in place: 13%, 5% and 0% for certain supplies of goods and services.

• From 2025 the threshold for VAT registration is raised to EUR 60,000.
• Many types of payments are subject to withholding tax, such as salaries, dividends, interest and other
• Croatian residents – natural persons are subject to income tax on their worldwide Non-residents are taxed on income generated in Croatia.
• Real estate tax is paid on real estate transactions (purchase, replacement, gift, ). A tax exemption may be applicable subject to certain conditions.

Key Tax Points

• Companies resident in Cyprus are subject to corporation tax on active income at 5%: non-resident companies only on profits derived from Cyprus. Branches managed and controlled from Cyprus are taxed as resident companies.
• Capital gains tax applies to residents and non-residents disposing of immovable property situated in Cyprus, and shares in companies owning such assets.
• VAT is charged on taxable supplies and imports at the standard rate of 19%. A reduced rate, zero rate and exemption regime applies to the supply of certain goods and services.

• In the absence of a tax treaty, the tax paid on overseas income in a non-treaty country is normally allowed as a tax credit by concession and proof of payment. The tax credit may not exceed the Cyprus corporation tax on the overseas income.

• Cyprus tax resident individuals are subject to income tax on worldwide income, non-residents are subject to income tax on Cyprus-sourced income only. Certain tax deductions are in place.

• Cyprus tax resident and domicile individuals are subject to defence contributions on dividend, interest and rental Cyprus tax residents who are not Cyprus domiciles are exempted from defence contribution on their passive income (dividends, interest and partly rent).
• An individual is considered of a Cyprus domicile if he/she has a domicile of origin in Cyprus based on the provisions of the Will and Succession Examples of domicile may include domicile of the parents at the time of birth or permanently living and intending to live in a country.
• Notwithstanding the above, an individual who although not of a Cyprus origin has been a Cyprus tax resident for 17 out of the last 20 years, prior to the relevant tax year, is considered as a Cyprus domicile.

Key Tax Points

• Czech resident companies are subject to tax on their worldwide Non-resident companies are subject to tax on income originating in the Czech Republic.
• Capital gains are not taxed separately but are included in ordinary
• VAT is applied to the supply of goods, the transfer of real estate, and the provision of services and The standard VAT rate is 21% and the reduced VAT rate is 12%.
• Transfer pricing rules apply to non-arm’s-length profit sharing arrangements agreed between related
• Real estate tax is levied on land and
• Ordinary foreign income tax credits are available to Czech taxpayers if a relevant double taxation treaty is in If there is no tax treaty, the foreign tax is included in the tax expenses for the following period.

• For 2024, the personal income tax rates are 15% and 23%. The 23% rate applies to the excess part of income that exceeds three times the annual average wage (CZK 1,582,812 for 2024). The rate of 15% applies to a separate tax base, in particular for foreign income from capital assets.
• In addition to income tax, employees also pay social security and health insurance contributions at the rate of 6%, which the employer deducts from their gross salary. The employer’s share of social security and health insurance premiums represents an additional cost of 33.8% of the gross salary.
• Withholding tax applies to dividends, royalties, interest and related income.

Key Tax Points

• Danish resident companies are subject to corporate income tax on Danish profits (including gains) and to some extent on foreign-sourced income. Non-resident companies pay tax on income sourced in Denmark.
• Branches of foreign companies are subject to tax on income derived from activities in
• Danish companies within a group, along with Danish permanent establishments and real estate owned by foreign subsidiaries are subject to compulsory Danish joint taxation.
• Value added tax is applied at a standard rate, but subject to zero-rating and Danish legislation generally follows EU Directives.
• A property tax is levied
• A controlled foreign company (CFC) system operates to attribute profits of a foreign subsidiary to a Danish parent where the activities of the subsidiary are mainly financial.
• Unilateral and tax treaty relief are available for foreign tax levied on profits subject to Danish corporate income
• Dividends, interest and royalty payments are subject to withholding tax, unless exempted under a relevant double tax
• Individuals resident in Denmark are taxable on worldwide income, non-residents on Danish-sourced
• A special basis of assessment is available for some expatriates employed temporarily in Denmark for a maximum of 84 months.

Key Tax Points

• In Djibouti, the main taxes are : Value Added Tax (VAT), Domestic Consumption Tax (TIC), Tax on salaries (ITS), Minimum Lump- sum Tax (IMF), Business Profit Tax (IBP), and Withholding tax (WHT).
• Resident companies in Djibouti (Eurl, Sàrl, SA, SAS) are subject to income tax at 25% on net profits and also to business licence tax.

• Non-resident companies in Djibouti but operating on Djibouti territory are subject to tax on profits derived from within the country.

• Capital gains are taxed in the same way as standard income (Business Profit Tax (IBP) at 25%. The capital gains tax is settled upon realisation of the capital gain.
• The Minimum Lump-sum Tax is applicable on realised turnover excluding VAT and is set at a rate of 1%. It is due if it exceeds the amount of the tax on profits or in case of a loss. The minimum IMF is DJF 120,000.
• There are two main tax incentive schemes for investors. Regime A and Regime B. Regime A relates to investments with a minimum amount of DJF 5 million (approximately USD 28,000) and Regime B to investments with a minimum amount of DJF 50 million (approximately USD 280,000).
• As of 2023 two new schemes were introduced: micro companies (0 to 5 employees with a revenue of DJF 2 million or less) and small companies (0 to 10 employees with a revenue of DJF 5 million or less). In order to be eligible for these schemes one must be Djiboutian and be receiving funding from an organization. The new schemes are tax-exempt for the first two years.
• Further to the 2024 Finance Act of 2024 a 5% withholding tax on dividends and interest paid to residents and non-residents is introduced, unless the amount paid out is less than JDF 10 million.

Key Tax Points

• The corporate tax system is based on the territoriality principle. Corporate income tax is only due on business income generated by enterprises operating in the Dominican Certain types of investment income derived by Dominican residents from sources outside the Dominican Republic are also subject to Dominican taxation.
• Non-resident companies operating through a permanent establishment in the Dominican Republic are taxed on income attributable to the permanent establishment as well as on Dominican-sourced Non-residents without a permanent establishment in the Dominican Republic are taxed on Dominican-sourced income only.
• Companies are subject to the higher of corporate income tax (at 27%) or alternative minimum tax (1% of the total asset value after deducting depreciation).
• The standard rate of VAT is 18%.

Key Tax Points

• The regular corporate income tax rate is 30%. The minimum tax payable is 1% of the annual turnover for larger
• The standard VAT rate is 16%.

Key Tax Points

• Corporate tax is payable by Ecuadorian resident companies on non-exempt income derived from all Non-resident companies are required to pay tax on income sourced in Ecuador.
• The corporate tax rate is 25%.
• Value Added Tax (VAT) is applied at a standard rate of 15% to all transactions including There is a 0% rate on food items, agricultural inputs, medical goods, books and government purchases, and some professional services.

• No provisions exist for filing consolidated returns or relieving losses within a
• Dividends paid to resident individuals and companies and to non-resident individuals and companies are subject to a 25% withholding The tax base will be 40% of the distributed dividends. Royalties, services, and rental fees are subject to the same 25% withholding tax.
• Income tax is payable by Ecuadorian resident individuals on non-exempt income derived from all Non-resident individuals are required only to pay tax on Ecuadorian-sourced income.

Key Tax Points

• Egyptian resident companies are taxable on their worldwide income, except for profits derived from permanent establishments abroad. Non-residents are only taxed on Egyptian-sourced income.
• Dividends paid to residents and non-residents are not subject to withholding Companies and individuals are not taxed on dividends received from resident companies but are taxed on dividends and other payments from non-residents.

• A credit system is available for relief of double taxation on foreign source The credit is subject to a maximum of the Egyptian tax paid on the overseas income concerned.
• There are provisions in place which limit the tax deductibility of interest based on the rate of interest charged and the debt-to- equity ratio of the company concerned.
• Transfer pricing rules are based on at arm’s-length An advance pricing arrangement is available.
• Domestic tax law provides for a 20% withholding tax applicable to the payment of interest and royalties to non-residents. Double tax treaties with various countries reduce the rate of withholding tax to be applied.
• General sales tax is payable on the supply of goods and services and The standard rate of tax is 10% although rates vary from 0% to 30%.
• Resident individuals are subject to income tax on their worldwide income whereas non-residents are taxed on Egyptian-sourced income.

Key Tax Points

• The general corporate income tax rate is 30% for resident and non-resident A reduced corporate income tax rate of 25% applies for companies whose taxable income is less than USD 150,000.
• Services and goods are subject to 13%
• Dividends, profit shares and similar benefits paid by resident companies to non-resident companies are generally subject to a 5% final withholding tax.
• Salvadorian-source interest, commissions, fees and other financial expenses, technical services, insurance premiums, and royalties paid for the use of patents, formulae, trademarks, privileges or franchises to non-resident companies are subject to a 20% final withholding tax.

Key Tax Points

• Estonian resident companies do not pay tax on their profits until they are distributed to The taxable period is the calendar month.

• There is no separate capital gains Gains derived by resident companies or branches of foreign companies are exempt until a distribution is made.
• Value added tax applies to most goods and
• Local taxes are imposed by only a few
• Foreign tax is mostly relieved by exemption by virtue of the provisions of double tax treaties with most overseas
• Withholding taxes apply only to certain royalties and in special cases (fees to artists and sportsmen from Estonian source).
• Income tax applies to individuals at a single, flat rate.

Key Tax Points

• Company income tax in Eswatini is a 25% (27.5% before 2024) flat rate on the taxable profit as adjusted for income tax purposes.

• Resident and non-resident companies are subject to income tax on income accrued or derived from Different rates apply to resident and non-resident companies.

• Effective 2024 a capital gains tax on disposal of business assets was
• VAT Act no. 12 of 2011 was introduced in Eswatini on 1 April 2012. VAT is chargeable on imports and the supply of goods and services in It is imposed at 15% on most goods and services supplied by a vendor. Certain goods and all exports are zero rated. Exempt supplies are provided for in the first schedule and zero rated supplies are provided for in the second schedule of the said VAT Act.
• There is no wealth tax, real estate tax or inheritance tax, sales tax or gift tax in
• Relief for double taxation is provided by means of a credit for overseas tax suffered on overseas
• A final 15% withholding tax is levied on dividends distributed by resident companies to non-resident companies while the rate is reduced to 12.5% in respect of dividends paid to a company registered or incorporated in Botswana, Lesotho, Namibia or South Africa, which is not a branch of a company registered or incorporated outside these countries.
• A 15% (10% before 2024) final withholding tax is levied on interest paid to non-resident Various exemptions are provided.

• A 15% final withholding tax is levied on royalties, technical fees, and management fees paid to non-resident
• Eswatini has entered into a limited number of double tax treaties with certain countries, including Lesotho, the Seychelles, South Africa, the United Kingdom, Taiwan and Mauritius.

Key Tax Points

• The standard corporate income tax rate is 30%.
• The standard VAT rate is 15%.
• Ordinary losses resulting from the excess of total allowable deductions over the total business income of the corporate body may be carried forward for up to 5 years. Loss carry-back is in principle not allowed.
• Dividends paid to non-resident companies are subject to a 10% final withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

• Interest payments to non-resident companies are subject to a 5% final withholding tax rate in the case of interest earned on savings deposits with financial institutions and 10% on the gross amount of interest earned in other cases, unless a lower tax treaty rate applies.
• Royalties derived by a non-resident companies are subject to a 5% final withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

• Technical services and management fees paid to non-resident companies are subject to a 15% withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

Key Tax Points

• The standard corporate tax rate is 25% (15% for companies listed on the South Pacific Stock Exchange).
• Losses incurred in a financial year starting on or after 1 January 2019 can be carried forward for up to 8 years (4 years before 2019). Losses cannot be carried back.
• According to domestic tax law, as of 1 August 2017, there is no withholding tax on dividends paid to non-
• Interest paid to non-residents is subject to a 10% final withholding tax on the gross
• Royalties paid to non-residents are subject to a 15% final withholding tax on the gross
• Management fees, professional fees or other independent services, and rental income (i.e. on films) paid to non-residents are subject to a 15% final withholding tax on the gross amount.
• Effective from 1 August 2023, VAT was removed from 22 basic food items (including medicine) to cushion the impact of high global prices on Fijian Consumers.

Key Tax Points

• Finnish resident companies are liable to corporate income tax on worldwide Non-resident companies are taxed on their Finnish-sourced income only.

• The Finnish Tax Administration is mainly using OECD guidance as a source of interpretation in cross-border situations (for instance in tax treaty matters).
• The Finnish Tax Administration has been strict in its interpretation regarding the constitution of a permanent establishment in income taxation, especially regarding home-office and remote work.
• The corporate income tax rate is 20%.
• Capital gains are normally taxed as ordinary In specific circumstances, capital gains arising on the disposal of shares in a subsidiary are exempt.

• In principle, all sales of goods and services are subject to value added tax, subject to reduced rates and The general VAT rate is 25.5% since September 2024.
• A local real estate tax is levied on properties owned by
• The transfer of immovable property is subject to a transfer
• A controlled foreign company (CFC) system
• Under double tax treaties, foreign tax is most frequently relieved by way of the foreign tax credit method, although sometimes the exemption method is also applied. Where there is no relevant tax treaty, Finnish domestic tax law grants a credit for foreign tax paid once that foreign tax is final.
• Dividends and royalties paid to non-resident companies are subject to withholding Tax treaties may provide benefits and exemptions to this.
• Interest paid to non-residents is generally exempt from
• Finnish resident individuals are subject to tax in respect of their worldwide Non-residents are taxed on their income derived from Finland.

• Individuals are taxed separately on earned income and investment income.

Key Tax Points

• Companies are subject to French corporate tax on the profits of any business carried out in France (currently 25% plus a 3% surtax applied to corporate income tax exceeding EUR 763,000). There is also a reduced rate for SMEs majority owned by individuals (subject to conditions).
• Capital gains generated by companies are generally deemed to be ordinary Under the participation exemption, 88% of the gains derived from the disposal of qualifying shares are tax exempt, if shares are held for more than 2 years.
• For individuals, capital gains are subject to a 30%/34% rate with potential lower rates applicable to the sale of shares of certain “young companies”.
• The standard tax system is territorial and applies to each company Foreign branch profits are exempt from French corporate tax. French branches of foreign companies will generally only be taxed in France on French-sourced income.

• In general, all supplies of goods and services and importations of goods and most services are subject to Value Added Tax (VAT) at a standard rate of 20% in mainland France.
• Territorial Economic Contribution: this contribution contains two elements: a tax on real estate utilized by the business (CFE) and a tax on the added value generated by the company (CVAE). Planned for 2027, the 2025 Finance Act postpones the definitive cancellation of the Tax rates will be gradually reduced from 2026 and the CVAE will be completely repealed in 2030. An additional contribution (“contribution complémentaire”) has been introduced in 2025 to make up for the loss caused by the reduction in the rate of CVAE. It is payable by persons liable for CVAE in respect of 2025 and amounts to 47.4% of the CVAE due.
• Other significant government levies include: a land tax (based on the rental value of real estate) and residential tax on the occupation of property. From 2024, the residential tax only applies to secondary properties.
• French or foreign legal entities that hold, directly or indirectly, one or more properties or property rights in France on 1st January must pay an annual tax equal to 3% of the market value of these properties or property rights. Exemptions are available under certain conditions.
• Transfer pricing requirements apply to related party transactions with overseas Certain transfer pricing documentation must now be provided annually.

Key Tax Points

• The standard corporate income tax rate is 30%.
• VAT is levied at a standard rate of 18%.
• Losses arising from normal business activities may generally be carried forward for up to 5 However, deferred depreciation in the loss-making year may be carried forward indefinitely. Loss carry-back is not allowed.
• Dividends paid to non-resident companies are subject to a 20% final withholding tax on the gross amount, subject to the application of a double tax treaty. Reduced rates are also in place.
• Interest derived by a non-resident company is subject to a 25% (20% before 1 January 2024) final withholding tax on the gross amount, subject to the application of a double tax treaty. Reduced rates are also in place.
• Royalties, technical fees, and management fees paid to non-resident companies are subject to a 25% (20% before 1 January 2024) final withholding tax rate on the gross amount, subject to the application of a double tax treaty.

Key Tax Points

• Corporation tax is payable based on the higher of 27% of chargeable profits or 1% and 2% of turnover for audited and unaudited accounts respectively.
• Value Added Tax (VAT) at a standard rate of 15% is payable on taxable supplies made in the Gambia, taxable imports of goods and on taxable supplies of imported services.

• Gambian-source dividends paid to non-resident companies are subject to a final withholding tax at the rate of 15% on the gross amount.

• Gambian-source interest paid to non-resident companies is subject to a final withholding tax at the rate of 15% on the gross amount.

• Gambian-source royalties paid to non-resident companies are subject to a final withholding tax at the rate of 15% of the gross amount.

• Gambian-source management, consultancy, technical services and public entertainment fees paid to non-resident companies are subject to final withholding tax at the rate of 15% on their gross amount.

• Fees on technical services rendered by non-resident contractors and sub-contractors during the exploration and appraisal stages of petroleum operations are subject to withholding tax on the gross amount at the rate of 10%.

Key Tax Points

• There are six main taxes in Georgia: Personal Income Tax (PIT), Corporate Income Tax (CIT), Value Added Tax (VAT), Import Duty, Excise Tax, and Property Tax.
• Companies incorporated and tax residents in Georgia (tax residents) are subject to tax on their worldwide income, whereas companies incorporated overseas are normally treated as non-resident taxpayers and are taxable only on Georgian-sourced income or income arising from business activities carried on through a permanent establishment (PE) in Georgia.
• Georgian and foreign enterprises are subject to CIT on their taxable profits at a flat tax rate of 15%. Companies must file individual tax returns and report their taxes Consolidated tax returns are not permitted. In most cases generated profit is not subject to tax, unless distributed through dividends.
• VAT applies to supply of goods or services in Georgia and imports (in accordance with customs value of goods). The standard VAT rate is 18%.
• Property Tax is a local tax administered by local self-government bodies (up to a maximum limit specified within the Georgian Tax Code (hereinafter the TCG)) and comprises land tax and property tax of individuals and enterprises.
• Individual residents and non-residents of Georgia are subject to PIT only on Georgian sourced Standard PIT flat rate is 20%, although lower rates might apply to specific economic activities based on applicable statuses.

Key Tax Points

• Companies resident in Germany are subject to tax on all of their Non-resident companies are subject to tax on German-source income.

• Business enterprises operating in Germany are also subject to a trade tax on business income, as assessed by each municipality.

• There is no separate capital gains tax for enterprises – broadly, capital gains from business assets are taxed at the ordinary tax rate. Capital gains realised by a corporate shareholder on the sale of shares held in an enterprise are almost tax free.
• VAT is applied on the supply of goods and services in Germany by a taxable person, subject to
• Profits of foreign companies may be attributed to German shareholders under a controlled foreign companies (CFC)
• A transfer pricing regime imposes record-keeping requirements and provides for income to be adjusted on an arm’s length basis.

• Capital gains realised by individuals or partnerships are added to annual income, subject to a 40% participation exemption on the sale of shares held as business assets. Roll-over relief may be available where gains are reinvested in shares.
• Dividends paid to residents and non-residents are subject to a 25% withholding tax, although this is reduced to nil in certain circumstances under the EC Parent/Subsidiary Directive or a Double Tax Treaty.
• Both personal and corporate income taxes carry a surcharge at the rate of 5% of the tax. The surcharges on personal income tax will only be levied on income above a certain threshold (taxable income exceeding EUR 73,483 per annum) and on capital gains (regardless of the threshold).
• Income tax is payable by German resident individuals on their worldwide Non-resident individuals are only required to pay tax on German-sourced income.

• Assets transferred by gift or inheritance are subject to Other taxes include an annual real estate tax, an insurance tax and a church tax.

• Real estate transfer tax is payable on the transfer of German real The amount depends on the federal state in which the property is located.

• There is a reporting obligation for intermediaries and taxpayers for reportable cross-border arrangements (Germany’s national transposition of the EU-Directive (DAC 6)).

Key Tax Points

• The assessment period in Ghana is the calendar year (i.e. January to December). Companies and bodies of persons are allowed to choose their accounting year.
• Companies that are resident in Ghana are liable to income tax on income earned domestically and from foreign Tax credit from foreign sources is allowable as tax credits domestically.
• Non- resident companies are liable to tax only on income with a source in
• Companies deemed as permanent establishments are liable to tax on all source of taxable
• The basis of assessment is the net profit of the This is adjusted by tax laws to arrive at the chargeable income.
• Repatriated branch profit is taxable at 8%.
• There is no separate rate for capital gains and gifts for companies. Income from the realisation of assets is subsumed in corporate income for tax Individuals may elect and apply a 25% tax on gifts received other than in respect of business or employment.
• Local production and importation of goods and services attract Businesses with annual income of between GHS 200,000 and GHS 500,000 are required to register for and charge VAT. There is no obligation to register if you deal in exempt supplies. Ghana currently has four VAT rate regimes:
  1. Zero-rated supplies
  2. 3% flat rated supplies
  3. 5% flat rated supplies
  4. 15% standard rated

A special rate of 3% applies under the VAT flat rate scheme. The Scheme applies to registrable wholesalers and retailers. Under the Scheme, a supplier is not entitled to an input tax deduction. The 3% flat rate is increased by a 1% Covid-19 Levy making it 4% in aggregate.

VAT on other supplies ( importers, manufacturers, wholesalers and retailers with annual turnover exceeding GHS 500,000) is at a 15% standard rate, calculated on the value of chargeable supply plus a 2.5% National Health Insurance Levy, 2.5% GetFund Levy and 1% Covid-19 Levy.

Effective 1 January 2024, a special rate of 5% VAT applies on the supply of immovable property for rental purposes, other than for accommodation in a dwelling or in a commercial rental establishment.

• Transfer pricing regulations apply to related party
• Subject to treaty agreements and exemptions, various withholding tax rates apply to payments made for transactions between companies resident in Ghana and non-residents.

• Subject to exemptions that may be available, resident individuals pay tax on income (cash and kind) earned in Ghana and abroad. Non-residents are taxed only on income with a source in Ghana.
• Statutory and voluntary pension deductions apply to employment
• There is no wealth or inheritance tax due in However, municipal authorities charge property rates.

Key Tax Points

• A company is taxed on profits which accrue, or are derived, in Gibraltar for a financial year at a rate of 15%, increased from 12.5% with effect from 1 July 2024 (although the rate can be 20% in some cases).
• Profits of foreign companies including branches that are tax residents in Gibraltar are taxed at the same rate as resident companies.

• There is no capital gains tax in
• There is no VAT in
• The tax year runs from 1 July to 30 June and tax is payable on the actual taxable profits for the year. For tax purposes, individuals can elect between the Allowance and Gross Income Based The standard rate of tax for individuals is 20%.
• As from 1 July 2024 Gibraltar minimum wage increased from GIP 60 to GIP 8.90 per hour.
• For accounting periods ending on or after 1 July 2024, the assessable income audit threshold increased from GIP 1,500,000 to GIP 1,750,000.

Key Tax Points

• Companies resident in Greece are subject to corporate income tax on their worldwide Non-resident companies are liable for tax on income derived through a permanent establishment in Greece.

• There are no special rules for groups and each company is taxed However, for transactions between group companies, transfer pricing rules should be adhered to.

• Capital gains are treated differently for company taxation purposes and individual taxation For company taxation purposes, all gains are considered to be derived from business activities. Specific tax rates apply to capital gains obtained by individuals.
• VAT is imposed on the sale of goods and supply of services at a standard rate of 24%. There is also a reduced rate of 13% and an extra reduced rate of 6%.
• Company’s profits are taxed at 22%. In addition, dividends are subject to a dividend tax of 5%.
• Many types of payments are subject to withholding tax (including payments for salaries, interest and royalties).
• Greek residents are subject to income tax on their worldwide Non-residents are taxed on net income sourced in Greece.

• An annual real estate tax is imposed on the value of real estate property, subject to certain conditions.

Key Tax Points

• The corporate income tax rate is set at a flat rate of 28%.
• Grenadian resident companies are taxed on their income earned in Non-residents are taxed on the profits of branch operations in Grenada.
• There is no tax on capital gains derived by companies although a transfer property tax applies as well as a Stamp Duty charge in respect of certain transactions.
• Withholding taxes are charged on payments to non-residents of dividends, royalties and other charges at a rate of 15%.
• Individuals who are resident, ordinarily resident or domiciled in Grenada pay income tax only on income earned in Non-residents are subject to tax on income arising from the carrying on of a business in Grenada. Withholding taxes apply to other payments to non-residents.

Key Tax Points

• Companies are subject to income taxes, known as the income on lucrative activities regime, at a rate of 25% on net taxable income.

• Solidarity tax is a way to anticipate income taxes so that the amount paid may be credited to income taxes over the following three years.

• VAT is payable on the domestic supply of goods and services and the import of A standard rate of 12% applies although some supplies are exempted.

• For income from entities not residing in the country and acting with or without a permanent establishment, tax regimes do exist for the specific computation of withholding tax at rates ranging from 5% up to 15%.

Key Tax Points

• Companies are subject to income taxes, known as the income on lucrative activities regime, at a rate of 25% on net taxable income.

• Solidarity tax is a way to anticipate income taxes so that the amount paid may be credited to income taxes over the following three years.

• VAT is payable on the domestic supply of goods and services and the import of A standard rate of 12% applies although some supplies are exempted.

• For income from entities not residing in the country and acting with or without a permanent establishment, tax regimes do exist for the specific computation of withholding tax at rates ranging from 5% up to 15%.

Key Tax Points

• The general corporation tax rates in Guyana are:
  • o 40% on the chargeable profits of a commercial company (other than a telephone company); and
  • o 25% on the chargeable profits of non-commercial
• VAT is levied at 14%.
• Unlimited loss carry-forward provided that it does not reduce taxable income in any year by more than 50% for non- commercial companies and below 2% of turnover for commercial companies. Loss carry-back is not allowed.
• A limited unilateral double taxation relief is
• Branch remittance tax is 20%, subject to the application of a double tax
• Dividends, interest, royalties and fees are generally subject to a 20% withholding tax unless a double tax treaty or multilateral treaty applies.

Key Tax Points

• Legal entities are subject to 25% income tax, known as the income from profit-making activities
• Legal entities and individuals resident in Honduras are subject to the Alternative Minimum Tax (AMT). From 2020, companies that carry out general activities generating more than HNL 1.1 billion will be subject to the AMT at a rate of 1%, while companies that carry out special activities generating more than HNL 1.1 billion will be subject to AMT at a rate of 0.50%. Special activities include natural or legal persons who produce or market: cement, public services provided by state-owned companies, medicines, petroleum and its derivatives, the bakery sector or industry, steel-derived products for construction, and the production, marketing, and export of coffee.
• Solidarity Tax is paid at a rate of 5% based on net taxable income exceeding HNL 1 million and is applicable only to taxpayers liable for income tax from profit-making activities (25% income tax regime).
• VAT is paid on the domestic supply and import of goods and services A standard rate of 15% applies, although a number of exempt supplies are in place.

• Transfer Pricing (TP) policies are applicable in Honduras. If the company does not conduct a TP study, the government is entitled to determine the differences between related party transactions and a transaction done by independent If a difference is detected, this would not be deductible for income tax purposes and a 15% or 30% tax would be payable on the difference.
• No restrictions are imposed on foreign-trade operations or foreign currency transactions, but these may be subject to certain tax regulations.

Key Tax Points

• Profits tax is charged on any person (including a corporation, partnership or individual) carrying on a trade, business or profession in Hong Income derived from outside Hong Kong is generally exempt (subject to rules deeming certain receipts to be derived from Hong Kong) regardless of residence status.
• Property tax is charged at 15% on the net assessable value of any land or buildings in Hong
• The transfer pricing (“TP”) regime was enacted and came into effect in Mandatory TP documentation is required based on the three-tiered structure recommended by the Organisation for Economic Co-operation and Development (“OECD”).
• Under the Foreign-sourced Income Exemption (“FSIE”) regime, foreign-sourced passive income (i.e. interest, intellectual property (“IP”) income, dividends and disposal gains from the sale of IP or non-IP assets) accrued to a member of an MNE group (“MNE entity”) carrying on a trade, profession or business in Hong Kong may be deemed to be sourced from Hong Kong and chargeable to profits tax.
• Under Pillar Two of the Base Erosion and Profit Shifting (“BEPS”) 2.0 initiative, a global minimum tax rate of 15% is imposed on large multinational enterprise (“MNE”) groups with annual consolidated revenue of EUR 750 million or above in at least two of the four fiscal years immediately preceding the current fiscal To facilitate the implementation of Pillar Two of the BEPS 2.0 initiative in Hong Kong, the bill seeking to implement the Global Anti-Base Erosion (“GloBE”) rules and Hong Kong minimum top-up tax was gazetted on 27 December 2024.
• Dividends received by a Hong Kong corporate are generally exempt from tax, unless they are within the scope of the FSIE regime. Dividend payments made by Hong Kong resident companies are not subject to withholding tax.
• There is no VAT or sales tax in Hong
• There is no capital gains tax in Hong Kong, and capital gains are generally not subject to personal or corporate income tax (unless they are within the scope of the FSIE regime).
• There is no inheritance tax or estate duty in Hong Kong.

Key Tax Points

• Companies resident in Hungary are taxed on their worldwide income. A company is resident in Hungary if it is incorporated or has its place of management Non-residents carrying on business through a branch or permanent establishment are taxed on income of the branch or establishment.
• Corporate income tax is levied at 9% of the tax
• Capital gains of companies are treated as
• Local taxes include a local business tax at a maximum rate of 2%.
• There is a range of tax incentives for investment, including special incentives for small and medium-sized
• Transfer pricing rules allow adjustment of taxable profits in respect of transactions between related
• VAT at 27% applies to the supply of goods and services while reduced rates or exemptions apply to certain
• Individuals resident in Hungary are taxed on their worldwide Non-residents are taxed only on Hungarian-sourced income.

Key Tax Points

• Companies resident in India are subject to income tax on their worldwide income and capital Non-resident companies are generally subject to income tax on their income from Indian sources.

• Dividend distribution tax payable by the Company has been abolished from tax year 2020-21 With effect from 1 April 2020, dividends distributed by companies shall be taxable in the hands of shareholders.

• Transfer pricing rules provide for income or expense or interest arising from international transactions among associated enterprises to be computed at an arm’s length basis.
• Authority for Advance Rulings was discontinued and replaced by Board for Advance Rulings (‘BAR’) with effect from 1 April 2021.

• There is also a mechanism of unilateral and bilateral Advance Pricing Agreements (APA mechanism) for transfer pricing transactions.

• The profits of small businesses or professions may be subject to presumptive taxation; income is deemed to be a percentage of gross receipts in case of presumptive taxation.
• There is no inheritance tax and wealth
• Any person earning taxable income from India, should obtain PAN (Permanent Account Number) and file income tax return in India (subject to certain exceptions).
• Angel tax is cancelled on investments made by non-resident investors in Indian private companies with effect from 1 April 2025.

Key Tax Points

• Companies resident in Indonesia are subject to income tax on their worldwide income including capital A permanent establishment of a foreign company is subject to tax in Indonesia on its worldwide income.
• Branch profits are taxed at the same rate as corporate A 20% withholding branch profit tax is also payable on after tax income in addition to the corporate tax, subject to the application of a double tax treaty.
• Indonesian individuals are taxed on their worldwide
• Non-resident companies are subject to tax on income, including capital gains, derived from
• On 31 December 2024, the Indonesian government introduced Regulation of the Minister of Finance Number 131 of 2024 (PMK 131/2024), which further outlines the adjustments to the application of VAT provisions. This regulation, effective 1 January 2025, specifies VAT treatment for the import and delivery of taxable goods and services within the customs area.

VAT rate for luxury goods

• The VAT rate applicable to luxury items stays at 12%. However, this applies only to goods classified as luxury under the Sales Tax on Luxury Goods, which includes certain motor vehicles, luxury residences, airplanes, and cruise For transactions involving final consumers, the 12% rate will be effective from 1 February 2025.

Effective VAT rate of 11% for non-luxury goods

For goods not classified as luxury, the VAT rate of 12% will be calculated by multiplying the applicable rate by a value factor of 11/12. This adjustment results in an effective VAT rate of 11%. This rate applies to non-luxury goods and is in line with maintaining the same VAT burden for these items as before.

• For export of taxable goods and services the VAT rate still remains the same at 0%. Note that the 0% VAT rate on export of services must meet the requirements as stipulated under Ministry of Finance (MoF) Regulation 81 of 2024 (refer to Section VAT below for a detailed explanation).
• There is a sales tax on the transfer or importation of luxury goods, currently levied at rates between 10% and 95%.
• Stamp duties apply to the transfer of land, and certain documents are subject to Stamp
• Double tax relief credits are generally available to Indonesian residents in respect of overseas tax paid on foreign-sourced income, up to a maximum of the Indonesian tax payable on the income concerned.

• Generally, residents are subject to a creditable withholding tax of 15% on payments received from fellow Indonesian residents, while dividends – subject to certain conditions – are exempted from tax based on Law of the Republic of Indonesia No. 11 of 2020 on Job Creation.
• Payments to non-residents are generally subject to a 20% final withholding tax, subject to the application of a double tax treaty.

• Based on The Minister of Finance Regulation 81 Year 2024, taxpayers can now use a tax deposit to make a tax payment by way of an overbooking (pemindahbukuan) process. A tax deposit refers to a payment made to the taxpayer’s account in the The Director General of Taxes that has not yet been assigned to a specific tax liability.

Key Tax Points

• Companies are broadly subject to a fixed corporation tax rate of 15%.
• Capital gains are treated as part of the ordinary income of companies and taxed at the appropriate corporation tax
• There is no Value Added Tax (VAT) or Goods and Services Tax (GST) in
• Related party transactions are required to be reported separately and should be made on a third party arm’s length Where prices paid for the purchase of goods or services are excessive or unreasonable, the Tax Authority can disallow a deduction for the excess portion.
• Resident and non-resident individuals are subject to personal tax at progressive tax rates up to 15%. Resident individuals can claim relevant exemptions whereas no exemptions are available to non-resident individuals.

Key Tax Points

• Irish corporation tax is payable by Irish resident companies on their worldwide income and
• Non-resident companies are taxed on income or gains from Irish specified assets and on income or from a branch or agency in Ireland.

• All Irish companies incorporated after January 2015 are deemed resident in Ireland, unless the company is considered tax resident in another country under a Double Taxation Agreement (‘DTA’).
• A company not incorporated in Ireland may also be deemed Irish resident if its central management and control resides in
• The standard rate of corporation tax is 5% and generally applies to trading income. Passive income, such as rent and investment income, is generally taxed at 25%. Capital gains of companies are, broadly, taxed at 33%.
• Ireland has signed up to the OECD’s new global minimum effective tax rate of 15% which is set to apply to companies with turnover in excess of EUR 750 Legislation has been introduced to bring these rules into effect on a phased basis with the first rules applying to financial years ended on or after 31 December 2023 with a return filing deadline of 30 June 2026.
• Ireland has implemented interest limitation rules and anti-reverse hybrid
• VAT applies to supplies of goods and services by taxable The standard rate of VAT is 23%.
• A double tax credit is generally available to Irish companies in respect of overseas taxes suffered on foreign
• Payments of interest, royalties and rent to non-residents are, in certain circumstances, subject to withholding tax at 20% (subject to the relevant double tax treaty).

• Payments of dividends are, in certain circumstances, subject to withholding tax at 25% (subject to the relevant double tax treaty).

• Individuals who are resident, ordinarily resident and domiciled in Ireland are subject to income tax on worldwide income and to capital gains tax on worldwide gains. Irish residents who are not domiciled in Ireland, are taxed on a remittance basis in respect of overseas income and gains.
• There is specific anti-avoidance legislation for transfer pricing and controlled foreign companies in Ireland.

Key Tax Points

• Companies resident in the Isle of Man (IoM) are subject to corporate income tax (CIT) on their worldwide
• There are three CIT rates in the A 10% rate applies to banking businesses and companies that derive income in excess of GBP 500,000 from retail activities. A 20% rate applies to companies which derive income from IoM situs land and property. A 0% corporate income tax rate applies to most other income.
• There is no capital gains tax in the IoM and furthermore, gains are not included in ordinary taxable
• The VAT rules in the IoM are nearly identical to those applying in the The standard VAT rate is 20% (with the exception of hotel accommodation and certain building works which are taxed at 5%).
• Double tax relief is available for foreign tax
• There are no specific transfer pricing
• There are no specific thin capitalisation or CFC
• Income tax is payable by IoM resident individuals on their worldwide A non-resident is generally taxed on their IoM sourced income.
• There are no death duties, estate duties or taxes on gifts although there are potentially significant probate charges.

Key Tax Points

• Israeli resident companies are liable to Israeli taxes on their worldwide income and capital A non-resident company is only liable to Israeli tax on income sourced in Israel.
• VAT is charged at a rate of 17% on the supply of goods and services by Israeli business
• Withholding taxes are deducted from payments of interest, dividends and royalties made to non-residents, subject to double tax treaty arrangements.

• Income tax is payable by Israeli-resident individuals on income derived from all sources, including passive income and all income derived or paid from overseas sources.

Key Tax Points

• All resident companies are subject to corporate income tax (IRES) on income from any source, whether earned in Italy or abroad. Non-resident companies are subject to IRES only on income earned in Both resident and non-resident companies are subject to regional income tax (IRAP) on income arising in Italy.
• Capital gains realised by a company are generally taxable as normal business income subject to IRES and IRAP, albeit certain reliefs may apply as per next paragraph description.
• Italian tax law includes a comprehensive set of rules on controlled foreign companies (CFC).
• VAT is levied on transfers of goods and services by enterprises, in the course of their business or professions within Italy, and on all imports into Italy.

• Foreign taxes may generally be credited against the Italian IRES tax liability, provided an equivalent clause exists in the territory from which the income derives.

• Transactions with foreign affiliated companies are closely scrutinised in order to determine whether transfer prices are at arm’s length.

• Domestic companies making certain types of payments (e.g. interests, royalties, professional fees ) are required to withhold taxes at various rates.

• Resident individuals are subject to a personal income tax (IRPEF) on their worldwide Individuals carrying on a business or profession and/or partnerships are liable to IRAP which is not deductible from IRPEF. Non-resident individuals are subject to tax only on their Italian-sourced income.
• There is wealth tax in Italy applied on the cadastral value of real estate (ranging from 86% to 1.14%): IMU. It is not applied to real estate used as a main residence. Gift and inheritance tax applies at rates dependent on the relationship that the person receiving the gift or inheritance has with the donor/testator.

Key Tax Points

• The standard corporate tax rate is 25% while a 30% rate applies to companies operating in the telecom, information technology and communication sector.
• VAT is levied only in respect of business activities that are carried on Ivory Coast territory at a standard rate of 18%.
• Withholding tax on dividends paid to non-resident companies is levied at 10% at the level of listed The rate is 15% for dividends derived from profits which are exempt from CIT and any other distributions.
• The standard withholding tax rate on interest paid to non-resident companies is 18%.
• Royalties, technical assistance fees and management fees paid to non-resident companies are subject to the tax on non- commercial profits by way of a final withholding tax at the rate of 25% of 80% of the gross amount of the royalties, resulting in an effective tax rate of 20%.

Key Tax Points

• Jamaican resident companies are liable for income tax on all sources of non-exempt income wherever
• A non-resident company is taxed on income of a branch carrying on a trade or business in Jamaica, e. the income arises in Jamaica.
• The tax year of ‘year of assessment’ is a period of twelve months commencing on 1st January in each
• There is no income tax on capital gains secured on the disposal of capital However, there is a transfer tax of 2% of gross consideration or market value when title passes. This 2% rate of transfer tax is effective from 1st April 2019.
• Branches of non-resident corporations or companies doing business in Jamaica are taxed on the profits arising in The income tax rate is 25% for an unregulated entity and 33 1/3% for a regulated entity.
• General Consumption Tax (GCT) is generally imposed at the standard rate on the supply of goods or services in Jamaica by a ‘registered taxpayer’ and on the importation of goods or services by any person for consumption in The standard rate of GCT was reduced from 16.5% to 15% effective 1 April 2020.
• The chargeable income of a company is determined by deducting all non-capital disbursement and expenses wholly and exclusively incurred in acquiring the income from all taxable income brought into Domestic and private expenses are not allowable deductions.
• There are no exchange controls in Jamaica at this
• Non-residents are subject to tax on income arising from
• Personal Tax: An individual who is resident, ordinarily resident and domiciled in Jamaica is subject to income tax on his worldwide income as it Income is taxed at a zero rate for the first threshold of JMD1,500,096 from 1 April 2017 to 31 December 2023, JMD1,650,090 for 2024 and JMD1,700,088 from January 2025. The income above the threshold but below JMD6,000,000 is taxed at 25% and income in excess of JMD 6,000,000 is taxed at 30%.

As of 1 January 2013, there is also a pension exemption of JMD 80,000 increased to JMD 207,530 for 2024 and JMD 250,040 from 2025, for pension received from either a statutory pension scheme or an approved retirement scheme. Further, there is an age exemption of JMD 80,000 increased to JMD 207,530 for 2024 and JMD 250,040 from 2025, for an individual who attained the age of 65 at any time during the year of assessment for which the return is being made.

Key Tax Points

• Domestic corporations whose head or main office is located in Japan are subject to tax on their worldwide
• Foreign corporations are subject to either corporation tax or final withholding tax on Japanese source income depending on the type of income and the extent of the foreign corporation’s activities in Japan.
• Vendors are liable for a consumption tax (value added tax) at a rate of 10% on sales (8% on sales of certain foods/beverages and newspapers), including imports of goods and services.

• Relief of double taxation is available for foreign taxes on certain foreign-sourced
• Under the group tax relief regime, which replaces the consolidated tax regime and is introduced from fiscal years starting on or after 1 April 2022, an affiliated group of companies (‘Group Corporations’) can calculate corporate income tax as if they are consolidated.
• All transactions between related companies are required to be conducted on an arm’s length basis.
• Domestic corporations are subject to withholding tax on dividends, interest and certain other Foreign corporations are subject to withholding tax on dividends, interest, royalties, income from immovable property, rentals from industrial or commercial equipment, and certain other income.
• Non-resident individual taxpayers are taxed on their Japanese source income only. Non-permanent resident individual taxpayers are taxed on income other than foreign-sourced income defined under Japanese income tax law plus the part of foreign-sourced income that is paid in and/or remitted to Permanent resident individual taxpayers are taxed on their worldwide income.

Key Tax Points

• There are no capital taxes, capital gains, inheritance, gift or wealth
• Residents are subject to Jersey income tax on their worldwide income as it arises. The standard rate of Income Tax is 20%. There are special rates of income tax for incoming high net worth individuals that meet certain For such individuals, the first GBP 1,250,000 of income is liable to tax at 20% and income in excess of this amount at 1%, with a minimum tax charge of GBP 250,000 applying in all cases.
• Non-residents are normally only subject to income tax on employment income (other than directors fees) arising in Jersey and rental income arising in Jersey. Trading income arising from a permanent establishment is also taxable, but generally at 0%.
• Goods and Services tax (GST) is charged on the supply of goods and services in Jersey by a business established in Jersey business at a rate 5%.

• Double taxation relief is available in accordance with various Limited unilateral relief is available for foreign earnings and certain dividends received by companies.

• A company tax resident in Jersey is chargeable to tax at 0%, 10% or 20% depending upon the nature of its Generally trading companies and investment holding companies are taxed at 0%. Certain financial service companies are liable to tax at the 10% corporate rate. Utility companies and companies with Jersey rental income and Jersey property development companies are taxed at 20%. Large “retail” businesses carried on in Jersey, where the company has turnover exceeding GBP 2,000,000 and profits of at least GBP 500,000, are also taxed at 20%.
• Non-resident companies are not liable to Jersey tax unless trading in Jersey or receiving income from land and property in Jersey.

Key Tax Points

• Every person with one or more taxable income sources shall submit a tax return according to the form approved by the Tax Authority by the end of the fourth month following the end of the tax period.

• Domestic companies are subject to income tax on worldwide income, while foreign companies are subject to tax on income from Jordanian sources only.

• Special rates of corporate income tax apply to certain industries including transport, construction, banking and other financial industries.

• Capital gains are taxed at the appropriate corporation tax rate if the assets are subject to depreciation rules.
• Credit for foreign taxes is generally only available where a relevant double tax agreement is in place.
• No withholding tax is charged on the payment of dividends by Jordanian However, withholding taxes are charged on the payment of interest, royalties and other charges to both residents and non-residents.
• Income tax is payable by residents and non-residents on salaries earned from any employment in Jordan.

Key Tax Points

• Standard corporate income tax rate is 20%.
• VAT is levied at a standard rate of 12%.
• Dividends, interest and royalties paid to non-residents without a permanent establishment in Kazakhstan are subject to 15% withholding tax, subject to the application of a double tax treaty. Dividends, interest and royalties paid to non-residents registered in a tax haven jurisdiction are subject to 20% withholding tax. Technical service fees and management fees are subject to 20% withholding tax. However, certain technical fees may be reclassified as royalties and thus be subject to 15% withholding tax only.
• Branches are subject to corporate tax at a rate of 20% on their net income. A 15% branch remittance tax also applies to net income after corporate tax regardless of whether the net profit is remitted to the head office but subject to the application of a double tax The effective tax rate for the income of branches of foreign legal entities therefore amounts to 32% if there is no reduction under a the application of a double tax treaty.

Key Tax Points

• Resident and non-resident companies are subject to income tax on income accrued in or derived from Kenya at different rates.
• The general corporate income tax rate for resident companies is 30%. From 1 January 2024, the rate for branches or PEs of foreign companies is also 30% (previously 37.5%).
• Branch repatriation tax: 15% with effect from 1 January 2024.
• Capital Gains Tax (CGT) is applicable at a rate of 15% on the net gain on the transfer of property in It is a final tax and cannot be offset against other income taxes.
• VAT is chargeable on imports and the supply of goods and services in Kenya. The standard rate is 16%. Certain goods and all exports of goods and services are zero-rated. Some goods and services such as unprocessed agricultural products and financial services are VAT exempt.
• Digital Service Tax (DST) is applicable at the rate of 1.5% of the gross transaction value of income of non-resident persons without a permanent establishment in Kenya earned from users in Kenya of services that are provided over the internet or an electronic network including through a digital marketplace. This took effect from 1 January 2021.
• Kenyan resident individuals are taxed on Kenya-sourced income and on income from employment or services rendered abroad.
• Non-resident individuals are taxed on any income from employment with, or services rendered to, an employer resident in Kenya or the permanent establishment in Kenya of a non-resident employer.

• Dividend Distribution Tax at the corporate income tax rate of 30% is applicable on distributions out of untaxed gains in the form of dividends.

• Broader definition of control and a permanent establishment in Kenya for the purpose of determining arm’s-length price in related party transactions and charging tax on income derived from or accrued in Kenya Control entails ownership of at least 20% of the shares or voting rights of a company. Moreover, control arises when a person advances loans to another person which constitutes 70% of the book value of the total assets or guarantees at least 70% of the total indebtedness of the other person or appoints more than half of the board of directors/ at least one director/executive member of the governing board. It also arises when a person or his designate person supplies at least 90% of his sales to another person or purchases at least 90% of the sales of another person as the Commissioner deems the influence in price to be.
• A permanent establishment is created when there is a fixed place of business through which business is wholly or partly carried on and includes a place of management, a branch, an office, a factory, a workshop, a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, a warehouse related to a person whose business is providing storage facilities to another person, a farm, plantation for agricultural activities; or a building site, construction site, assembly or installation project or any supervisory activity connected to the site or project which has existed for a period of 183 days or an aggregate of between 30 to 183 days or more than 30 days if the connected activity is being conducted by one or more enterprises closely related to the first-mentioned enterprise; or provision of consultancy services within Kenya for an aggregate period of 91 days per year; or an installation/structure used to explore natural resources which continues for more than 91 days; or an agent who negotiates and concludes contracts on behalf of the person.
• Income tax at the rate of 15% applicable on gains accruing to a non-resident person on derivatives transactions accrued in the Kenyan financial derivatives market.

Key Tax Points

• Foreign corporate bodies engaged in commercial activities in Kuwait, directly or through an agent, are taxed. The taxable presence of a foreign entity is determined by whether it carries on a trade or business in Kuwait and not on whether it has a permanent establishment or place of business in Kuwait.
• The individuals (Kuwaiti or Foreign national) and Kuwaiti companies wholly and directly owned by Kuwaiti individuals and companies incorporated in the Gulf Cooperation Council (GCC) countries that are wholly owned by GCC citizens (GCC entities) are tax exempt.
• Tax is levied on the foreign company’s share of profit, irrespective of whether distributed or not, royalties and franchise, license, patent, trademark and copy right fees received by foreign company are also taxable.

• The tax authorities deem a profit margin for materials and services from outside Kuwait through the head office:
  • Materials 15% of revenue;
  • Design 25% of revenue; and,
  • Consulting 30% of
• The Tax authorities deem a profit margin for materials and services from outside Kuwait through related parties:
  • Materials 10% of revenue;
  • Design 20% of revenue; and,
  • Consulting 25% of
• The Tax authorities deem a profit margin for materials and services from outside Kuwait through third parties:
  • Materials 5% of revenue;
  • Design 15% of revenue; and,
  • Consulting 20% of
• Foreign companies operating in Kuwait through an agent, through a joint venture, as a shareholder in W.L.L. or K.S.C. Companies or through Foreign Direct Investment Law should obtain a taxation card. All Individuals, Kuwaiti entities (W.L.L. or S.C. or Companies listed in the Kuwait stock exchange) that are not owned by foreign companies need not apply for the taxation card.
• The taxation card must be renewed every The taxation card is valid from January to December every year even if the company has a different year end.
• In the event of a failure to file a tax declaration by the due date, a penalty that equals 1% of the tax for each 30 days or fraction thereof during which the failure continues is In addition, in the event of a failure to pay tax by the due date, a penalty that equals 1% of the tax payment for each period of 30 days or fraction thereof from the due date to the date of settlement of tax due is imposed.

Key Tax Points

• Domestic and non-resident companies alike are subject to a 20% profit tax (effective as of 1 January 2020).
• Dividends, interest and income from security fees paid to non-resident companies are subject to a 10% withholding tax.
• Income from patents, copyright, trademarks or other intellectual property is subject to a 5% final withholding tax.
• As from 1 April 2024, the standard VAT rate was reinstated to 10% (the VAT rate had been reduced from 10% to 7% effective 1 January 2022 in light of the COVID-19 pandemic).

Key Tax Points

• In accordance with the Corporate Income Tax Law corporate income tax is paid at the moment of the distribution of profits (including at the moment of the deemed profit distribution). Undistributed corporate profits are tax exempt. Corporate income tax (CIT) rate is 20% on the gross distributed amount or 20/80 on the net income, i.e. the taxable base subject to CIT has to be divided by a 8 coefficient, thus giving an effective rate of 25%. The described tax regime applies to Latvian resident companies as well as to permanent establishments of non-resident companies that are registered in Latvia.
• The general VAT rate is 21%. A reduced rate of 12% and 5% is applied to certain products and Intra-community supply of goods (to a customer registered as a VAT payer in another Member State) is zero-rated.
• Non-arm’s length transactions with related parties are treated as a deemed profit distribution.
• Withholding tax is levied at standard rates on certain payments made by Latvian residents to non-residents. If a double tax treaty exists between Latvia and the relevant country, reduced rates or exemptions may apply.
• Latvia has a progressive personal income tax The progressive rate is based on the level of annual income.

Key Tax Points

• Income tax in Lebanon is levied on the territoriality principle, as in general all income derived from Lebanon is subject to tax.
• Generally, companies (as well as branches of foreign companies) are subject to a flat 17% income tax on profits.
• Public work contractors, oil refineries, insurance companies and transport companies, if subject to taxation, are taxed on the basis of a “lump-sum profit method”.
• The standard VAT rate is 11%
• Holding companies are exempt from income tax on profits and are subject to only an annual lump-sum tax of LBP 50 million.
• Offshore companies are exempt from income tax on profits and are subject to only an annual lump-sum tax of LBP 50 million.

Key Tax Points

• A company is liable to tax separately from its members, and dividends are only taxable if they are from unqualified income. A manufacturing company is taxed at a special rate of 10% on profits whilst a non-manufacturing company is taxed at a standard rate of 25% on profits.
• Capital gains and losses: A taxable gain or loss on disposal of an asset is the difference between its adjusted cost base and proceeds. No tax implication arises from the disposal of assets, such as a private residence or motor vehicle, provided they are not used in the production of income subject to tax.
• A branch of a non-resident company in Lesotho is subject to tax at the standard rate of tax of 25% on repatriated income in addition to income tax on the chargeable income of the branch.
• VAT is a broad based tax levied on the supply or consumption of goods or services including supplies to the government. It is also levied on imported goods and Only registered persons can operate VAT and registration may be on a compulsory, mandatory or voluntary basis. The VAT registration threshold is LSL 850,000. There are several VAT rates in place: 0%, 10% and 15% (standard rate).
• Subject to any applicable treaty, Lesotho-source dividends, interest, royalties and management charges paid by a resident company to a non-resident company are generally subject to a withholding tax rate of 25%.
• Subject to any applicable treaty, withholding tax is levied at a rate of 10% on the gross amount of a payment made to a non- resident company under a Lesotho-source service contract.
• Personal tax is based on An individual is a resident if they have a place of abode in Lesotho, are present in Lesotho for more than 182 days in any consecutive period of twelve months (which includes all or part of the year of assessment), are an official of the Lesotho Government posted overseas during the year of assessment or have a resident lifestyle. Non- residents would pay tax on Lesotho source income at a standard rate of 25%.

Key Tax Points

• The standard corporate income tax rate is 25% while the petroleum and mining income tax rate is 30%. An additional 20% surtax is payable by high-yielding (i.e. when the project’s pre-tax rate of return on total investment is greater than 22.5%) mining projects on the positive net accumulated cash-flow at the close of a year of assessment and is a deductible expense for income tax purposes.
• Losses can be carried forward 5 years for general companies and 7 years for specific Losses cannot be carried back.
• Dividends, interest, royalties, and technical and management fees paid to non-residents are in principle subject to a 15% withholding tax. The rate may differ for mining, petroleum and renewable resource projects.
• VAT is levied at a standard rate of 10%. Reduced rates of 0% and 7% may also apply in certain cases.

Key Tax Points

• Companies are subject to corporate tax at a rate of 20% applied to their taxable income and Jehad tax at 4% of taxable income.
• Employment (salaries and wages) tax is calculated on an employee’s base salary plus any allowances at a maximum rate of 10%. Other taxes levied on personal income include a Jehad tax at 3% of taxable salary income and a Solidarity Fund contribution at 1% of taxable salary income.
• Social security contributions (INAS) are payable by all employees working in Libya whether local or foreign, based on gross income with a total of 20.5% (5.125% employee contribution, 15.375% employer contribution).
• Capital gains are treated as ordinary business income and taxed at the general corporate income tax rate of 20%.
• Libya does not impose any Value Added Tax (VAT).

Key Tax Points

• Luxembourg resident companies are subject to tax on their worldwide Non-resident companies are taxable in Luxembourg only on certain Luxembourg-sourced income.
• For tax year 2025, corporate income tax (“CIT”) is levied at a rate of 12%, if the taxable income is higher than EUR 200,000.
• Luxembourg resident companies and non-resident companies having a permanent establishment in Luxembourg are also subject to municipal business tax (“MBT”), which is payable at rates that vary depending on the municipalities (e.g. 75% for Luxembourg-city).
• VAT taxable persons performing supplies of goods or services should charge VAT (standard rate of 17%) on these supplies unless transactions are subject to a reduced rate, are exempt from VAT, or are outside of the VAT VAT may also be due on intra-UE acquisitions of goods and supplies of services as well as on import of goods.
• Capital gains are in principle regarded as ordinary business income and are taxed at the normal income tax Exemptions and roll-over relief apply in some cases.

• Net wealth tax (“NWT”) is charged on companies’ net assets value, after certain deductions (and exemption of certain assets).
• In certain cases, foreign income tax may be credited against domestic income tax up to the amount of the domestic Non- creditable portion of foreign income tax is considered a tax-deductible expense.
• Profits and losses of Luxembourg group companies may be pooled (tax unity) under certain conditions.
• Transactions by a company with shareholders and related parties must be at arm’s length
• In general, withholding tax is levied on dividends paid by resident Dividends paid to companies covered by the EU Parent-Subsidiary Directive are exempt under certain conditions. Subject to certain exceptions, neither interest nor royalties are subject to withholding tax.
• Resident individuals are liable to tax on their worldwide Non-resident individuals are only taxable on specific Luxembourg-sourced income.
• Inheritance tax and gift tax rates vary according to the degree of kinship of the persons involved and the value of the asset inherited/received, e.g., no direct-line inheritance tax.

Key Tax Points

• The standard corporate income tax rate is 30%. A 35% rate applies to foreign companies with a PE in
• VAT is levied at a standard rate of 5%.
• Losses may generally be carried forward for up to 6 Loss carry-back is not allowed.
• Dividends paid to non-resident companies are subject to a 15% final withholding tax on the gross amount. Dividends derived from a mining project are subject to a 10% withholding However, in practice, it is reported that all dividends are subject to 10% WHT.
• Interest derived by a non-resident company is subject to a 15% final withholding tax on the gross However, interest derived from mining projects is subject to a 10% withholding tax.
• Royalties, technical fees, and management fees paid to non-resident companies are subject to a 15% final withholding tax rate on the gross amount. However, royalties derived from a mining project are subject to a 10% withholding tax.

Key Tax Points

• Taxable income of companies is generally subject to corporate tax at the rate of 24%. To simplify and ease the administrative burden under the previous tax imputation system, a single-tier tax system has been introduced with effect from Year of Assessment (YA) 2008. Under this new system, income tax imposed on a company’s chargeable income is a final tax and dividends distributed are exempted from tax in the hands of the shareholders.
• Income tax in Malaysia is imposed only on Capital gains are not taxed, except those arising from transactions in real property or shares in Real Property Companies. With effect from 1 January 2024, the scope of income under the Income Tax Act has expended to tax gains or profits from the disposal of capital assets.
• A resident is taxed on income accrued in or derived from However, a resident company carrying on a business of banking, insurance or sea or air transport is also taxed on income derived from outside Malaysia and received in Malaysia. With effect from 1 January 2022, income derived from outside Malaysia (foreign-sourced income) and received in Malaysia by tax residents will be subject to tax. A concession is granted whereby foreign-sourced dividend income of a tax resident company or a limited liability partnership and foreign-sourced income of a tax resident individual will continue to be exempted until 31 December 2036.

• Tax incentives are given for Malaysian resident companies carrying on certain favoured activities including energy conservation services and the managing of Islamic funds.

• All manufacturers and importers are subject to sales tax. The basic rate of 10% applies to all goods not specifically exempted or taxed under a reduced (5%) or increased (15%) rate. Sales tax has been abolished and replaced by Goods and Services Tax (GST) with effect from 1 April However, GST has been repealed and Sales tax has come into effect again on 1 September 2018.
• Service tax is levied on prescribed goods and services provided by certain businesses, including hotels, restaurants, legal, accounting and insurance businesses. Service tax has been abolished and replaced by GST with effect from 1 April 2015. However, GST has been repealed and sales and service tax (SST) has come into effect again on 1 September 2018 with a rate of 6%. With effect from 1 March 2024, the service tax rate increased from 6% to 8% excluding food and beverages, telecommunication services, parking and logistic services and the taxable services expanded to include new types of taxable service. With effect from 1 May 2025, the scope of service tax will be expanded to include new services such as commercial services transactions between businesses (B2B), including fee-based financial services.

• Sales tax rate will be increased for non-essential items such as imported premium goods like salmon and avocado with effect from 1 May 2025.

• Malaysia has expanded the scope of its service tax on 1 January 2020 to include foreign service providers who provide electronic and digital services to Malaysian customers at the rate of 6%. If the value of the digital services rendered exceeds the threshold of MYR 500,000 for a period of 12 months, the Foreign Service Providers are required to register with the Royal Malaysian Customs Department (RMCD). With effect from 1 March 2024, the service tax for digital service increased from 6% to 8%.
• With effect from 1 January 2008, under the single-tier system all dividends distributed by the company are exempted from tax in the hands of shareholders at all levels. However, with effect from YA 2025, a dividend tax of 2% will be imposed on chargeable dividend income received by individual shareholders, where the annual dividend income exceeds MYR 100,000.
• Resident companies within a group of companies may enjoy group relief Up to 70% of the adjusted loss may be surrendered to companies within the group upon commencement of business subject to certain conditions.
• Under Section 140A of the Income Tax Act 1967 (the Act), the Director General of Inland Revenue (DGIR) is empowered to make adjustments based on arm’s length principle as set out under the Malaysian Transfer Pricing Guidelines revised in July 2017 on the transfer prices in relation to related party transactions. New and updated TP guideline, Income Tax (Transfer Pricing) Rules 2023 were introduced with effect from YA 2023 onwards.

• With effect from 1 January 2019, Earning Stripping Rules (ESR) have been introduced in Malaysia to be in line with BEPS Action 4: Limiting Base Erosion Involving Interest Deductions and Other Financial Payments to address base erosion and profit shifting by way of interest.
• There is no withholding tax on dividends paid by Malaysian resident There is withholding tax on payments of interest, royalties and technical fees made to non-residents, although there are exemptions for certain types of interest payment.
• Introduction of global minimum effective tax rate (ETR) at the rate of 15% with effect from 1 January 2025 as part of the Base Erosion and Profit Shifting (BEPS) 0 initiative. Global Minimum Tax (GMT) is aimed at MNCs (Malaysian-headquartered and foreign-headquartered) operating in at least 2 jurisdictions, with an annual consolidated group revenue of at least EUR 750 million in at least 2 of the 4 immediately preceding fiscal years. Two categories of MNCs need to be fully aware of the impact of GMT: (i) large Malaysian-based MNCs that have foreign operations and (ii) foreign-based MNCs that have operations in Malaysia.
• An electronic invoice must be issued for each transaction in respect of any goods sold or services performed, and it shall be transmitted electronically to and validated by the Malaysia Inland Revenue Board (MIRB). E-Invoice will be implemented in phases based on the turnover or revenue thresholds from 1 August 2024 to 1 July 2025.
• Foreign Source Income (FSI) of a Malaysian tax resident received in Malaysia from outside Malaysia with effect from 1 July 2022 is subject to income tax at the prevailing tax However, Malaysian individual tax residents are exempted from the imposition of tax from 1 January 2022 to 31 December 2036 on the following foreign source income received in Malaysia:
  • Dividend income received by locally incorporated/registered companies or limited liability partnerships, or individuals whose dividend income is in relation to a partnership business in Malaysia (excluding persons who are carrying on the business of banking, insurance or sea or air transport); or
  • All types of foreign source income received by individuals, except for a source of income from a partnership business in
• Malaysia Digital (“MD”) was launched on 4 July 2022, a rebranding of the former Multimedia Super Corridor (MSC Malaysia). The MD initiative serves to accelerate the sustainable growth of Malaysia’s digital economy and create substantial digital economic spill-over through equitable access to digital tools, knowledge, and income opportunities, driving digital transformation of focus areas that present high growth potential, opportunities, and importance.
• Real Property Gains Tax (RPGT) is charged on chargeable gains from the disposal of chargeable assets such as houses, commercial buildings, farms and vacant land and shares in a real property RPGT is imposed from a rate of 10% to 30% depending on the holding period of the chargeable assets.
• Stamp duties are imposed on chargeable instruments and payable by the buyer or The rate of duty varies (0.1% to 4%) according to the nature of the instruments/documents and transacted values. A self-assessment system for stamp duty was introduced, requiring duty payers to evaluate the value to stamp duties payable on their documents with progressive effect in phases from 1 January 2026 to 1 January 2028 based on types of instruments or agreements.
• A high-value goods tax at the rate of 5% to 10% imposed on certain high-value goods or luxury goods such as jewelry and watches, based on the threshold value of the goods, has been deferred until further notice.
• Sales tax on Low-Value Goods (LVG) imposed at the rate of 10% on the import of low-value goods sold online with effect from 1 January 2024.

• Incentives according to demographic region such as Iskandar Malaysia (IM), Northern Corridor Economic Region (NCER), EAST Coast Economic Region (ECER), Sarawak Corridor of Renewable Energy (SCORE) and Sabah Development Corridor (SDR) aimed to economic growth based on regions in Malaysia.
• Carbon tax on industry iron, steel and energy in Malaysia introduced with effect from YA 2026 to encourage adoption of low-carbon technology.

Key Tax Points

• The standard corporate income tax rate is 30%.
• The standard VAT rate is 18%.
• Losses can be carried forward for 3 Losses cannot be carried back.
• Dividends paid to a non-resident company are subject to a 10% final withholding tax on the gross amount.
• Interest paid to a non-resident company is subject to a final withholding tax ranging between 3% and 18%.
• Royalties paid to a non-resident company are subject to a 30% withholding tax reduced by 50%, giving rise to an effective final withholding tax of 15%.
• Service fees, including technical services, and management fees paid to non-resident companies are subject to a final 15% withholding tax on the gross payments.

Key Tax Points

• Malta’s tax system is based on UK principles and enjoys the approval of the EU Commission and Code of Conduct Group following Malta’s EU accession.
• Malta operates a full imputation system where dividends paid by a Maltese company carry a tax credit equivalent to the tax paid by the company on the distributed profits.
• Shareholders are taxed on the gross dividend but are entitled to tax credits of the tax paid by the company on the profits so distributed.

• Malta has an inheritance tax referred to as Causa Mortis, relating to a succession of an immovable property from the deceased.

• Taxpayers (both individuals and companies) who are ordinarily resident and domiciled in Malta are subject to income tax in Malta on their worldwide income and certain capital gains.
• Malta operates the “remittance basis” of taxation. Taxpayers who are either not ordinarily resident or are not domiciled in Malta are subject to tax on income arising in Malta and on foreign income only if that is received in In such case, foreign capital gains are not taxable in Malta even if received in Malta.
• Malta does not impose withholding tax on payment of dividends, interest or royalties, although there are some exceptions.

Key Tax Points

• The regular corporate income tax rate is 25%.
• Profits realised in Mauritania by branches of non-resident companies are deemed to be distributed and are therefore subject to a 10% branch remittance tax on after-tax income.
• Dividends paid to non-resident companies are subject to a final withholding tax at a rate of 10%, unless a lower rate in a relevant double taxation treaty applies.
• Interest paid to non-resident companies is subject to a final withholding tax at a rate of 10%, unless a lower rate in a relevant double taxation treaty applies.
• Royalties paid to non-resident companies are treated as income from the provisions of services and are subject to a final withholding tax at a rate of 15%, unless a lower rate in a relevant double taxation treaty applies.
• Remuneration paid to non-resident companies without a PE in Mauritania, for services rendered in Mauritania, is subject to a final withholding tax at a rate of 15%, subject to the application of a relevant double tax The withholding tax applies to natural persons, companies or any other legal persons who do not have a PE in Mauritania, but who:
  • carry out isolated operations in Mauritania;
  • exercise their activity through a representative in Mauritania who does not have a distinct personality; or
  • carry out a complete cycle of operations on Mauritanian
• The standard VAT rate is 16%. Exports are zero-rated.

Key Tax Points

• A corporation resident in Mauritius is subject to tax on its worldwide income. A non-resident corporation is liable to tax on any Mauritius source income, subject to any applicable tax treaty Corporations are liable to income tax on their net income, currently at a flat rate of 15%. As from 1 July 2019, a company will not be considered tax resident in Mauritius if it is centrally managed and controlled outside of Mauritius.
• As from year of assessment 1 July 2024, a Corporate Climate Responsibility (CCR) Levy of 2% is applicable on chargeable income of companies and resident societies with a turnover of more than MUR 50 The CCR Levy is applicable to companies holding a Global Business Licence (GBL) as well.
• Value-Added Tax (VAT) is charged by VAT registered entities at the standard rate of 15% on goods and services supplied by them in Mauritius. Certain supplies are exempted or zero-rated.
• Certain local taxes apply including excise duty, land and property taxes and customs duties
• Personal income tax is chargeable at a progressive rate starting from 2% to 20% on an individual resident in Mauritius. As from the income year starting on 1 July 2023, annual net income not exceeding MUR 390,000 derived by individuals resident in Mauritius will be subject to tax at 0%. Annual net income exceeding this amount will be taxed from 2% to 20% on a progressive scale.
• There is neither capital gains tax nor inheritance tax
• There is no stand-alone transfer pricing legislation, but the arm’s-length requirement is applied to related party transactions
• There is no specific thin capitalisation However, other anti-avoidance provisions may apply.

Key Tax Points

• The fiscal year in Mexico is on a calendar year basis
• All income obtained by Mexican residents is taxed in Mexico, regardless of the source (worldwide income tax basis).
• Every state in Mexico requires specific contributions from its inhabitants, the largest being income In some states employers are charged tax on wages paid to employees.

• Taxpayers with operations with related parties are obliged to demonstrate that such operations and profits were carried out according to market prices through a transfer pricing study, otherwise, the Mexican Tax Authority may adjust the operation for tax purposes and alter the tax loss or profit.
• A Controlled Foreign Companies regime (CFC) applies to transactions realised in specific countries or regions
• Persons will be subject to an additional tax of 10% on dividends or profits distributed by corporations resident in Also, foreign residents who receive dividends from Mexican corporations shall be required to make a 10% tax payment on such dividends.
• In case of income obtained abroad, the income tax paid abroad thereon is generally offset against income tax to be paid in Mexico, subject to certain rules and limitations.
• The Value Added Tax (VAT) rate is 16%, which is levied on purchases of goods, rendering of services, leasing and importation further to foreign trade operations and can be offset against VAT collected and payable (output VAT). A tax rate of 8% is applicable for the North and South Border Region under a Presidential Decree in force until 31 December 2024.

Key Tax Points

• Corporate income tax is levied at a rate of 12%.
• Capital gains are included in the company’s ordinary taxable income and taxed at a rate of 12%.
• The standard VAT rate is 20% while reduced rates of 12%, 8% and 0% are also in place.
• Losses may be carried forward for five successive tax periods and set off against taxable Losses may not be carried back.

• Dividends paid to non-resident companies are subject to a 6% final withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

• Interest payments to non-resident companies are subject to a 12% final withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

• Royalties derived by a non-resident companies are subject to a 12% final withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

• Technical services, management fees, and rental income paid to non-resident companies are subject to a 12% withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

Key Tax Points

Further to a profound tax reform, the key tax laws including General Law on Taxation, Corporate Income Tax Law, Personal Income Tax Law and VAT Law have been revised and adopted by the Parliament of Mongolia on 4 June 2019. The new tax laws came into effect on 1 January 2020.

• The corporate income tax (CIT) rate is 10% for income up to MNT 6 billion and 25% for the excess while certain types of income are taxed at specific CIT rate is 1% for business entities with annual turnover under MNT 300 million and certain qualifying conditions may apply.
• Dividends, interest, royalties and technical service fees paid to a non-resident are subject to a 20% withholding A 20% branch remittance tax also applies.
• Loss carry-forward period is 4 years without sector differentiation with a universal restriction of 50% of taxable profits in any tax year.

• The standard VAT rate is 10%.

Key Tax Points

• Moroccan corporations are subject to corporate income tax (“Impôt sur les sociétés”) or IS
• The standard rate of Value Added Tax (VAT) is 20% and applies to all suppliers of goods and services, except those taxed at other rates or those who are exempt. Reduced rates (7%, 10% and 14%) apply to specific items.
• Dividends paid to a non-resident are subject to a 15% withholding tax unless the rate is reduced under an applicable tax The rate is progressively reduced by 1.25% a year from 2023 to 2027 to 10%

• Interest on loans obtained from a non-resident is subject to a 10% withholding tax unless the rate is reduced under an applicable tax treaty.

• Royalties paid to non-residents are subject to a 10% withholding tax unless the rate is reduced under an applicable tax treaty.

Key Tax Points

• Resident corporations are subject to corporate income tax (IRPC) on their worldwide Non-resident companies with a permanent establishment in Mozambique are liable for IRPC on the income attributable to that permanent establishment.
• Resident individuals are subject to income tax on their worldwide income while non-residents are liable to income tax only on income sourced in Mozambique.
• The standard corporate income tax rate is 32%.
• Effective 1 January 2023, the standard VAT rate is 16% on the supply of goods and services in Mozambique and on the importation of goods.
• Dividend payments to non-resident companies are subject to a 20% final withholding A 10% rate applies to dividends distributed by companies listed on the Mozambique Stock Exchange to their non-resident corporate shareholders.
• Interest payments to non-resident companies are subject to a 20% final withholding
• Royalties paid to non-resident companies are subject to a 20% final withholding
• Services received by a non-resident company are subject to a 20% final withholding tax

Key Tax Points

• Corporate income tax is levied at the rate of 22% on income earned in MMK with effect from FY2021-2022
• There is no withholding tax on dividends paid to a resident or non-resident
• Interest is subject to a 15% withholding tax if paid to a non-resident. There is no withholding tax on interest paid to a resident.
• Royalties are subject to a 15% withholding tax if paid to a non-resident. Royalties paid to a resident are subject to a 10% withholding tax.

• There is no Value Added Tax (VAT), although commercial tax is levied as a turnover tax on goods and services, generally at a rate of 5%.

Key Tax Points

• Resident and non-resident companies are only taxable on sources of income arising and deemed to arise in Namibia
• Dividends received from any source are generally not taxed, dividends paid to non-residents are subject to NRST
• There are no donation taxes, estate duties nor taxes on capital gains
• Income Tax rate on non-mining companies: 31% (effective 1 January 2024), with a further reduction to 30% (effective 1 January 2025).

• Maximum Income Tax rate on individuals and trusts: 37% (on income in excess of NAD 55 million).
• Withholding taxes (final tax): interest earned by individuals 10%, interest paid to foreign persons 10% (subject to DTT), payment in respect of foreign service, including rentals of equipment: 10% (subject to DTT).
• Trusts are taxed as individuals, with the first NAD 100,000 taxable income per annum not being taxed.
• Freight tax has been introduced which is levied at 10% of the non-resident’s deemed income multiplied by the current corporate tax rate.

• The standard VAT rate is 15%. VAT applies to imports and the supply of goods and services in Namibia at 5%. Certain basic commodities are zero-rated, with a variety of services being exempt such as medical, financial and educational.
• Shareholders can be held personally liable for any tax debt of their company, as is any director or other senior
• Individuals and directors are subject to a payroll tax on earnings (PAYE).
• Persons exporting goods manufactured in Namibia, subject to exceptions, are eligible for an 80% reduction of taxable income derived from such exports.

Key Tax Points

• Nepalese resident companies are subject to corporate tax on income derived from all sources at the rate of 25% subject to certain exceptions on various bases as per section 11 of ITA.
• All entities that carry their transactions in Nepal are required to register for Value Added Tax (VAT) if their annual turnover meets the registration turnover threshold.
• Withholding tax is deducted from interest, royalties, dividends and other specified payments as per section 88 of ITA
• As per section 6 of ITA, Resident natural persons are taxed at all incomes from worldwide Non-resident persons are taxed on incomes having source in Nepal.
• Resident natural persons are taxed at a progressive rate
• Non-resident natural persons are taxed at a flat rate and subject to final withholding as per section 92
• Capital gains taxes are deducted as final withholding tax for non-resident persons and individuals and as advance tax for resident companies.

• Final withholding tax at the rate of 25% is levied on all windfall gains under section 88A of ITA
• When foreign-sourced income is included in assessable income, tax credits are available using the credit method/ expense method as per sec 71 of ITA

• Non-resident air or transport operators pay taxes on their gross collection through sales of tickets at the rate of 5%, where the first point of entry is Nepal. The tax rate is 2% of gross sales of tickets where the flights do not originate from Nepal.
• Dividends distributed by a foreign permanent establishment of a non-resident are treated as amounts repatriated and taxed at the rate of 5%.

Key Tax Points

• There is no special tax rate for capital gains, but gains and losses are included in the company’s taxable base
• Dividends distributed by a resident entity are in principle subject to Dutch dividend withholding tax
• As of January 2021 a (conditional) withholding tax on interest and royalties is in place to in principle low-taxed From 1 January 2024 this conditional withholding tax also applies to dividends.
• Under the participation exemption regime, dividend income and capital gains realised from qualifying shareholdings are exempt from corporate income tax.

• The Netherlands maintain an extensive investment and tax treaty network
• Dutch entities engaged in so-called back-to-back financing and/or licensing activities are subject to specific Dutch substance requirements
• The Netherlands has adopted the so-called ‘Danish cases’ into its anti-abuse legislation, thereby imposing substance requirements on foreign shareholding entities.
• Subject to certain conditions, group companies may form a ‘fiscal unity’ (group consolidation) for corporate income tax and/or VAT purposes.
• Companies and individuals are subject to a municipal tax on the ownership of real estate in the Netherlands based on market value. Acquisition of real estate in the Netherlands is generally liable to real estate transfer tax.
• Individuals resident in The Netherlands are subject to personal income tax on their worldwide income, with a credit for foreign taxes on foreign-sourced income either under double tax treaties or under Dutch unilateral rules. Non-residents are liable for Dutch personal income tax only for Netherlands sourced income.

Key Tax Points

• Income tax is payable by resident individuals on their worldwide Non-resident individuals pay tax on New Zealand-sourced income only.

• Income tax is payable by New Zealand resident companies on income derived from all Non-resident companies pay tax on income sourced in New Zealand. The tax rate for companies is 28%.
• There is no comprehensive capital gains However, where a capital asset is bought for the clear purpose of resale, any profits or gains are regarded as ordinary income. There are also specific income tax provisions in relation to certain land transactions and overseas financial investments that are similar to a capital gains tax.
• A broad-based, value added tax called goods and services tax (GST) is levied on the supply of goods and services in New Zealand at a rate of 15%.
• There is a controlled foreign company (CFC) regime, a foreign investment fund (FIF) regime, and there are transfer pricing and thin capitalisation rules.

• Credits are available in New Zealand for the lesser of foreign tax paid or New Zealand tax payable on foreign income, regardless of whether a Double Taxation Agreement (DTA) is in place, provided they are of the same nature as income The credits may be subject to limits imposed by DTAs.
• Where there is at least 66% common ownership, revenue losses can be transferred between New Zealand tax resident companies. Where there is 100% common ownership between New Zealand tax resident companies, dividends between companies can be exempt, consolidated returns can be lodged and revenue and capital items can be transferred. Company losses can be carried forward indefinitely so long as the same shareholders hold more than 49% of the shares from the date of the losses are incurred until they are Losses can also be carried forward where the company meets a new “same or similar business” test, even if the 49% shareholding continuity requirements have been breached.
• A look through company (LTC) regime exists whereby small closely held companies who elect to become an LTC must pass profit or losses directly to LTC losses are unable to be carried forward. A foreign company cannot be an LTC. Non- resident shareholders can hold shares in an LTC. However, if a non-resident holds more than 50% of the shares, any foreign- sourced income must not exceed the greater of NZD 10,000 or 20% of the LTC’s gross income for the year.
• Dividends, interest and royalties paid to non-residents are subject to non-resident withholding tax (NRWT) at varying rates.

Key Tax Points

• Corporate income tax is levied only on domestic-sourced income at a flat rate of the higher of 30% of net taxable income (i.e., gross taxable income less allowed deductions) or a final minimum tax of 1% to 3% on gross income obtained during the fiscal year
• VAT is levied at a rate of 15% on domestic taxable supplies of goods and services, and on imports and exports of goods and services. Exports of goods and services are zero-rated.
• Operating losses may be carried forward against operating profits of the subsequent 3 Loss carry-back is not allowed.
• Dividends, interest and royalties paid to a non-resident are subject to a 15% withholding The rate increases to 30% if the payment is made to a resident of a tax haven jurisdiction.
• There is no branch remittance tax in Nicaragua.

Key Tax Points

• The standard corporate income tax rate is 30%.
• VAT is levied at a standard rate of 19%.
• Losses may generally be carried forward for up to 3 years
• Dividends paid to non-resident companies are subject to a 10% final withholding tax on the gross amount. A reduced rate of 7% applies on dividends from companies quoted within the WAEMU (West African Economic and Monetary Union) area by the CREPMF (Regional Council of Public Savings and Financial Markets).
• Interest derived by a non-resident company is subject to a final withholding tax on the gross amount at the same rates as residents.

• Royalties and technical assistance fees paid to non-resident companies are subject to a 16% final withholding tax rate on the gross amount.

Key Tax Points

• The rate of Company Income Tax is 30% and 20% of total profit for large and medium companies respectively and 3% of assessable profit for education tax. Small companies are completely exempt from paying income and education taxes.
• Capital gains and losses are treated differently from regular business transactions of individuals, partnerships and companies in Nigeria. Gains arising from the disposal of chargeable assets are taxed at a rate of 10%.
• VAT is imposed on non-exempt supplies of goods and services within Nigeria as well as on goods The standard rate is 7.5%. Zero-rated goods and supplies are all non-oil exports.
• Dividends paid by a resident company to a non-resident without a PE are subject to a final withholding tax of 10% on the gross amount. The tax deducted is a final tax.
• Interest accruing to non-resident companies without a PE is liable to a deduction of tax at source of 10% of the gross The tax deducted is a final tax.
• Royalties derived by non-resident companies without a PE are subject to a withholding tax at 10% of the gross The tax deducted is a final tax.

Key Tax Points

• Companies resident in North Macedonia are subject to tax on their worldwide Non-resident companies are subject to tax on income sourced in North Macedonia only.
• With effect from 1 January 2008, corporate income tax is levied at a rate of 10%.
• VAT is applied on the supply of goods and services in North Macedonia by a taxable person, subject to exemptions. The standard rate is 18% and a reduced rate of 5% applies to specific goods and Starting from 2021 a reduced rate of 10% applies to restaurant and catering services.
• A transfer pricing regime imposes record-keeping requirements and provides for income to be adjusted on an arm’s-length basis. A report on transfer pricing and possible effects on income tax should be submitted with the Public Revenue Office at the latest by 30 September of the current year related to the previous year for companies that have total income equal to or over MKD 300 million and for transactions with non-resident related parties.
• Dividends, interest, royalties, technical fees, and management fees paid to non-resident companies are subject to a final withholding tax of 10% on the gross amount, unless a tax treaty provides for a lower rate.
• Resident individuals are subject to personal income tax on their worldwide income while non-residents are liable for tax on North Macedonian-sourced income With effect from 1 January 2023, individual income tax is levied at a flat rate of 10%, which will be applicable on an individual’s income from work, self-employment income, income from sale of own agricultural products, income from capital, rental income, insurance income, capital gains, income from royalties and industrial property rights, as well as other taxable income not categorised separately. With effect from 1 January 2023, capital gains are taxed at a rate of 10%. Before that date, capital gains were subject to a 15% income tax rate.
• Greenfield investments: Technological–Industrial Development Zones exempt to a large extent from taxes and other benefits: zero-rated personal and corporate income tax for up to the first 10 years (10% thereafter), no VAT and customs duties for export production, subsidy of up to EUR 500,000 for building costs, land lease for up to 99 years at attractive concessionary rates, free connection to utilities, Green Customs Channel expediting exports to the EU, advantageous location, access to pan- European corridors 8 and 10, railroad, and international airport.
• Brownfield investments may benefit from some tax exemptions regarding employees for about two years.

Key Tax Points

• The tax rate on income in Norway has gradually been reduced from 28% to 22% from 2014 to 2019. To offset the shortfall in revenues, tax on dividends has been increased correspondingly, keeping the combined tax on company revenue and dividends at approximately the same level, between 46.5 and 49.5%, however, increased to 51.5% for 2023, 2024, and 2025.
• Company tax is payable by Norwegian resident companies on income from all Non-resident companies pay tax on income sourced in Norway.
• There is no separate capital gains Capital gains are treated as ordinary income and capital losses are treated in the same way as trading losses.
• A credit is available for overseas tax payable against Norwegian tax on the same Foreign tax on business income may be deducted as an alternative to taking a tax credit.
• Group companies cannot file consolidated tax Where there is more than 90% common ownership, income can be transferred between resident companies as a means of off-setting profits with losses within the group.
• The arm’s-length principle generally applies to transactions between related parties.
• Withholding tax must be deducted from dividends paid to non-residents, although there is no withholding on dividends paid to corporate shareholders resident in and performing real economic activities in the Interest and royalties are not subject to withholding tax.
• Income tax in payable by residents on income derived from all Non-residents only pay tax on Norwegian-sourced income.

Key Tax Points

• A five-year tax holiday is available to manufacturing companies if certain conditions are met
• Capital gains are generally taxed as ordinary corporate income, although profits/losses on the sale of securities listed on the Muscat Securities Market are not taxable/deductible.
• Branches in Oman of foreign companies are subject to tax on their Allowance for allocated head office expenditure is on a restricted basis. Payment made by an Omani branch to a non-resident entity shall attract withholding tax even if the payment is made in the nature of head office global overheads.
• Withholding taxes apply at a rate of 10% on payment/credit to a non-resident entity with no permanent establishment in Oman receiving certain types of payments royalties, management fees, research and development, use or right to use computer software, and provision of services.
• There is no personal income or wealth tax in Oman.
• Value Added Tax (VAT) is implemented in Oman on 16 April The standard rate of VAT in Oman is 5% and consistent with the GCC Unified Agreement, and there are provisions for zero rating and exemptions in Oman VAT Law.
• Royal Decree 70/2024 issued regarding Supplementary Tax Law on Entities Affiliated with Multinational Groups.

Key Tax Points

• Income/Profits of corporate entities are taxed at 29% and companies falling under the small company category are taxed at 20%.
• The tax rates for branch office of non-resident company incorporated outside Pakistan are the same as applicable to resident companies. However, such branch office operating in Pakistan through a permanent establishment is also entitled to set off expenses incurred in or outside Pakistan for the purpose of business, including reasonable allocation of share of head office general and administrative expenses.
• Some sources of income are taxed on a presumptive tax basis, where the withholding tax suffered on such income constitutes full and final discharge of tax liability.
• In certain cases, withholding tax on services is considered to be a minimum Some other classes of taxpayers also have to pay minimum tax in relation to their turnover.
• Where a resident taxpayer derives foreign-source income on which income tax has been paid in the foreign territory, a proportionate tax credit is allowable in respect of that income in Such reduction is available, both in terms of provisions of Avoidance of Double Taxation Treaty, as well as unilateral relief, where such treaty is not available.
• Payment for expenses and procurements are subject to withholding tax deduction on various prescribed deduction Such withholding taxes deducted from suppliers, vendors, service providers and employees etc., are periodically required to be deposited in the Treasury.
• In certain cases, subject to eligibility and certain conditions, a Certificate of exemption from withholding tax can be obtained.
• In allowing expenses for the tax computation, some conditions, like payment through crossed cheque or through banking channels and compliance with withholding tax requirements do apply.
• All tax filings, tax payments, show-cause-notices, and assessment procedures are electronic and web based, and filing can be done from anywhere in the world through internet.
• All tax statements (returns) filed within due time are accepted under self-assessment, and the declared results are deemed to be an assessment. However, a certain percentage of the tax returns is selected and set apart for tax audit through computer balloting by the Federal Board of Revenue. Commissioners also have powers to select cases for audit.
• The Assessments completed on the basis of return can be amended on the basis of definite information, coming in possession of the tax officials, gathered through audit or otherwise. The assessment can also be amended, where it is considered to be erroneous and prejudicial to the interest of revenue.
• The tax authorities have the power in respect of a transaction between associates to distribute, apportion, or allocate income, deductions, or tax credits between such associates to reflect the income that would have been realised in an at arm’s-length transaction.
• VAT (locally termed as ‘sales tax’) is a federal tax, ordinarily levied at 18% on the value of goods, unless specifically exempt, or chargeable under reduced rate or zero rated. The tax is subject to input tax adjustments.

• Sales tax on Services, which is a provincial levy, is also charged by each Province, under its own laws. The entity having business or place of business in more than one province(s) is required to register and file separate tax returns for each such province. The tax rates range from 5% to 16% on the value of taxable services.
• Elaborate, multilevel appeal system is available, where a taxpayer feels aggrieved by any assessment or action of the tax authority.

Key Tax Points

• Corporate income tax is only chargeable on revenue arising from business activities and assets situated in Panama.
• An alternative minimum income tax system applies to all companies except small companies invoicing up to USD 1,500,000 per year.

• Tax is chargeable at 10% on the net profit arising on the sale of real estate A different tax calculation method applies on the sale of shares and securities.
• VAT is charged on the supply of goods and services at a standard rate of 7%, although some goods are subject to higher rates (elaborated upon in the tax sales section) while others are exempt.
• Withholding taxes apply to the payment of dividends by Panamanian companies to all Services and fees, interest, commissions, royalties, or technical assistance fees, etc., paid or accrued to foreign recipients are subject to withholding tax only if the local payer will take it as a deductible expense.
• All individuals are subject to income tax on Panamanian source Progressive tax rates apply (elaborated upon in the personal tax section).

• The study and reporting of transfer prices are mandatory for individuals and companies according to their area of operations when conducting transactions with foreign related parties and areas under a special tax regime.

Key Tax Points

• Papua New Guinea (PNG) residents are subject to income tax on their worldwide Non-residents are subject to income tax only on PNG source income.
• There is no separate capital gains Broadly, capital gains from the sale of property are taxed at the prevailing company tax rate while capital gains realised by a shareholder on the sale of shares held in a company are not subject to company tax.

• Goods and Services Tax (GST) is imposed at the rate of 10% on supply of goods and services in PNG, including imported goods and services unless subject to GST zero rating.
• A transfer pricing regime imposes record-keeping requirements and provides for income to be adjusted on an arm’s-length basis.

• Dividends paid to resident individuals, resident trusts and non-resident persons are subject to a 15% withholding tax
• Indirect taxes include import duty, stamp duty and betting tax.

Key Tax Points

• The standard corporate income tax rate is 10%. Additionally, a tax is levied at the rate of 8% on dividends or profit distributions accrued or paid.

• Losses can be carried forward for 5 years but cannot be carried The amount of tax loss offset is up to 20% of the net income obtained in the relevant subsequent year.
• Dividends or profit distributions made to non-resident shareholders are subject to a 15% withholding tax
• Interest payments made to non-residents, that are not related parties, are subject to a 15% withholding tax on 30% of the amount paid (effective rate of 4.5%).
• Royalties paid to non-residents are subject to a 15% withholding tax
• The standard VAT rate is 10% while a 5% rate applies to the sale of pharmaceuticals, the basic family basket and agricultural, horticultural and fruit products as well as to residence property rentals.

Key Tax Points

• Corporate Income Tax (CIT) is payable at a rate of 5% applicable from 2017 onwards.
• Value Added Tax is imposed on the sale of goods, the supply and use of services in the country and the import of goods made at different stages of the economic cycle. The general tax rate is 18%.
• Royalties and similar income are subject to withholding income taxes at source
• Peruvian citizens residing in Peru are taxed on their worldwide income, regardless of where the income is generated or where it has been paid or the currency received for it. In the case of non-resident citizens, they are taxed only on their Peruvian- source income.

Key Tax Points

• The tax year runs for the calendar year although approval of the Commissioner of Internal Revenue can be obtained for the adoption of a fiscal year.
• Company tax is payable by domestic companies on all income derived from sources within and outside the Foreign corporations, whether resident or non-resident, are taxable only on income derived from sources within the Philippines.
• Effective 1 July 2020, domestic corporations are generally taxed at 25% on taxable Domestic corporations may be taxed at 20% if the net taxable income does not exceed PHP 5,000,000 and total assets do not exceed PHP 100,000,000, excluding the land on which the particular business entity’s office, plant and equipment are situated.
• Effective 1 July 2020, resident foreign corporations are taxed at 25% based on net taxable income.
• Effective 1 January 2022, regional operating headquarters (ROHQ) are taxed at 25% on taxable income.
• Effective 1 January 2021, non-resident foreign corporations are taxed at 25% on the gross income from all sources within the Philippines.

• Effective 28 November 2024, corporations classified as Registered Business Enterprises under the enhanced deductions regime shall be taxed at 20% on their income derived from registered projects or activities during each taxable year.
• A 12% Value Added Tax (VAT) on the gross selling price or gross value in money or gross sales of the goods is imposed on all importations, sales, barters, exchanges or leases of goods or properties and sales of services
• Imposition of 12% VAT on digital services effective 1 February 2025.
• Tax credits are available for taxes and duties paid on purchases of raw materials of products for export, domestic capital equipment, and domestic breeding stock and genetic A number of Special Economic Zones, some of which are operated as separate customs territories also exist.
• Compensation income of residents is subject to tax at progressive rates of up to 35%.
• Individuals deriving income from business or the practice of a profession whose annual gross receipts/revenue is PHP 3 million and below have the option to be taxed at 8% on gross income in lieu of income tax and other percentage tax. If such income exceeds PHP 3 million the tax is levied at progressive rates of up to 35%.

Key Tax Points

• Polish resident companies are subject to corporate income tax on all sources of their worldwide Non-residents are taxed only on income derived from Poland.

• Real property tax and tax on the means of transport (lorries, tractors and trailers) are charged as local taxes.
• Civil law activity tax (CLAT) applies to contracts of sale, lease or hire, loan agreements, and foundation deeds of a partnership.
• Foreign tax paid may be credited against Polish tax due, up to the amount of domestic tax.
• A ‘tax capital group’ may be established by joint stock companies, simple joint stock companies and limited liability companies, where there is 75% ownership.
• Transfer pricing provisions apply to transactions carried out between related parties
• Withholding tax is deducted among others from dividends, interest, royalties, and intangible However, under the EU Parent-Subsidiary Directive, dividend distributions by resident subsidiaries to their non-resident EU parent or EEA parent are exempt subject to certain conditions.
• Individuals resident in Poland are taxed on their worldwide Non-residents are taxed only on the income derived from work performed in Poland.

• Tax on revenue from buildings – taxpayers who are owners of fixed assets that are buildings located in Poland – new tax rules enacted from January 2019.

• Split payment mechanism – payment for purchased goods or services is automatically divided into net sale and VAT accounts.
• MDR – obligation to report cross-border and domestic arrangements to the tax authorities

Key Tax Points

• Resident corporations are subject to Portuguese corporate income tax (CIT) on their worldwide income. Non-resident companies with a permanent establishment in Portugal are liable for CIT on the income attributable to that permanent establishment.
• Foreign-sourced income, gross of tax paid abroad, is included in taxable A unilateral credit for foreign income tax suffered can be set off against the Portuguese corporate income tax.

• Group taxation is available where all companies in the group are resident in The parent company must hold, directly or indirectly, at least a 75% shareholding in the remaining companies of the group.
• The standard rate of VAT is 23%. In addition, an intermediate rate of 13%, and a reduced rate of 6% are applicable to a range of goods and services.

• Transfer pricing legislation enables the tax authorities to make corrections to taxable income when the conditions (and prices) agreed between related parties are different from those that would have been agreed and accepted between independent entities (arm’s length principle).
• Resident individuals are subject to income tax on their worldwide income whilst non-residents are liable to income tax only on income sourced in A new special tax regime for non-habitual residents (NHR 2.0 – Tax Incentive for Scientific Research and Innovation) came into force from 2025 onwards. A special tax regime for individuals less than 35 years old (IRS Jovem) was also introduced in 2025, providing an exemption from PIT of salaries and wages earned during the first 10 years of activity, subject to certain conditions.
• Social security is due on remunerations at a 75% rate for the employer and 11% for the employee.

Key Tax Points

• Corporations pay the larger amount between the “Regular Tax” (with a maximum 5% tax rate) or the “Alternative Minimum Tax” (either an 18% or 23% tax rate).
• Certain corporations may be subject to the payment of either a “Deemed Dividend Tax” or a “Branch Profit Tax”.
• Corporations and limited liability companies can elect to be taxed as a “Flow-through Entity”. One member limited liability companies can elect to be taxed as a “Flow-through Entity” or as a “Disregarded Entity”. Special provisions apply for foreign limited liability companies.
• Individuals pay the larger amount between the “Regular Tax” (with a maximum 33% tax rate) or the “Alternative Basic Tax” (with a maximum 24% tax rate).
• Corporations, Flow-through Entities and Individuals rendering services, can elect to pay the “Optional Tax” (with a maximum tax of 20% on gross income) subject to certain requirements.
• A 5% Sales and Use Tax is levied on the sale and use of tangible personal property, taxable services, and admission rights in Puerto Rico. A reduced 4% rate applies for “Designated Professional Services” and “B2B Services”.
• Some local taxes include the Municipal Licence Tax, Construction Excise Taxes, and Real and Personal Property Taxes.
• Employer related taxes include the Unites States Social Security and Medicare taxes, the US and Puerto Rico unemployment taxes, Non-occupational disability insurance, Chauffeur’s insurance and Workmen’s compensation.
• There are no gift or estate taxes.
• Tax incentives provided by the Puerto Rico Incentives Code to “Eligible Activities” include: (i) 4% income tax rate on income from eligible activities; (ii) 50% municipal licence tax exemption; (iii) 75% real and personal property tax exemption; (iv) 0% tax for shareholders on distributions from eligible activities, with some Eligible activities conferring additional tax benefits and/or tax credits.
• The incentives Code confers on “Individual Resident Investors” the following tax benefits: (i) 100% tax exemption on interest and dividends; (ii) 100% tax exemption on after relocation capital gains on securities, commodities, digital currency, and other blockchain based assets; and (iii) 15% tax rate (or up to a maximum 24% if subject to the Alternative Basic Tax) for prior relocation capital gains on securities, commodities, currency, and other blockchain based assets if disposed within 10 years, and 5% tax rate if disposed after 10 years.

Key Tax Points

• An annual tax shall be imposed on the taxpayer’s taxable income derived from sources in the State during the previous taxable year. A flat 10% rate applies.
• Qatar has introduced a 15% global minimum corporate tax rate, in line with the OECD’s Inclusive Framework, affecting multinational enterprises that have branches in Qatar with global revenues exceeding QAR 3 This change does not apply to local entities or individuals.
• There is no sales tax, estate tax or gift tax in Qatar.
• Subject to the provisions of tax agreements, payments made to non-residents with respect to activities not connected with a permanent establishment in the State shall be subject to a final withholding tax of 5%.
• There are no personal taxes, social insurance or other statutory deductions from salaries and wages paid in However, income arising from business activities (rent from property, consulting, etc.) is taxable.

Key Tax Points

• Corporate income taxes are chargeable on resident companies as well as non-resident companies with a permanent establishment in Romania and on foreign legal entities resident in Romania according to the place of effective management.

• Capital gains are generally treated as ordinary business income and taxed accordingly.
• Residents and non-residents owning more than one building are subject to real estate tax.
• Dividends paid to non-resident companies are subject to withholding tax, subject to some Generally, dividends paid by resident companies to other resident companies are tax exempt.

• Transactions between legally related parties are subject to arm’s length requirements for tax Starting from 2016 proper transfer pricing documentation is mandatory for large taxpayers.
• There is no concept of group tax Profits and losses cannot be transferred between related parties. Starting from 2022, profit taxpayers are allowed to set up fiscal groups in which the profits and losses generated by the members are aggregated.
• Pillar Two has been implemented in Romania and applies to large national and multinational groups with consolidated revenues exceeding EUR 750 million in at least two of the previous four fiscal It establishes a minimum effective tax rate of 15%.
• The standard VAT rate is 19%, while also reduced rates of 9% and 5% apply to certain goods and services.
• Entities established in Romania, regardless of whether they are registered for VAT purposes or not, are required to issue invoices through the RO e-Factura system for transactions whose place of supply is considered to be in Romania from a VAT perspective.
• Taxpayers who carry out national road transportation of high tax risk products, as well as international road transportation of goods, are required to report thesein the e-Transport system, subject to certain conditions.
• Residents, and certain non-residents are subject to individual income tax on their worldwide income and capital gains.
• The obligation to transmit the standard fiscal control file (SAF-T) through the Informative Declaration D406 becomes effective for each category of taxpayers.

The Standard Audit File for Tax (SAF-T) is an international standard for the electronic exchange of accounting data between taxpayers and tax authorities. This standard was developed by the Organization for Economic Co-operation and Development (OECD) in 2005. Informative Statement D406 (SAF-T) is an electronic file, based on a .XML file type, internationally standardised for sending tax reports, from taxpayers to tax authorities.

Key Tax Points

• A resident company is subject to income tax on its worldwide A non-resident company is subject to tax only on income sourced in Rwanda through a permanent establishment in Rwanda.

• A foreign tax credit is granted for income tax paid on foreign-sourced income.
• The effective corporate income tax rate is 28% for both domestic companies and branches of foreign However, certain special categories of investors benefit from preferential corporate income tax rates of 0% and 15 %.
• A 15% withholding tax is levied on dividends, interest, royalties and technical and management fees paid by resident entities including tax-exempt entities.

Key Tax Points

• The corporate income tax rate is 33%. A branch remittance tax of 15% also applies.
• Capital gains are not taxable except if a capital asset is sold within one year from the date of acquisition, in which case a 5% capital gains tax is applicable (half of the corporate tax rate of 33%).
• VAT is levied at a standard rate of 17%.
• There is no withholding tax on dividends, interest, royalties and technical services and management fees paid to residents while such payments to non-residents are subject to a 15% withholding tax, which needs to be remitted to the Inland Revenue within 15 days.

Key Tax Points

• A resident company is taxed only on income earned in Lucia. A non-resident company is taxed on income derived or sourced from St. Lucia. The current standard corporate income tax rate is 30%.
• The standard rate for Value Added Tax (VAT) is 5% while a reduced rate of 10% applies to goods and services supplied by hotels and restaurants. A rate of 7% is applied for accommodation in the hotel sector.
• Taxes are required to be withheld from payments made to non-residents of an income nature and from payments to residents for labour contracts and certain services. For Caricom persons, the rate is 15%, for non-Caricom persons the rate is 25% and for residents the rate is 10%.
• Where an individual is a resident but is not ordinarily resident, his or her assessable income shall include income accrued from sources out of St. Lucia but only to the extent that such income is received in St. Lucia.

• For non-residents, taxable income means income generated in Lucia and income from activities performed in St. Lucia.

Key Tax Points

• Both resident corporation and non-resident corporations with a PE in São Tomé e Príncipe are in general subject to corporate income tax at the rate of 25%.
• A withholding tax of 20% is applicable on remittance of after-tax profits from the branch to its foreign head office
• The standard rate of VAT is 15%.
• Dividends, interest, royalties, and service payments to non-resident entities without a PE in São Tomé e Príncipe are subject to a final withholding tax of 20%.

Key Tax Points

• Saudi-Arabian resident companies, permanent establishments of non-resident companies in Saudi Arabia and non-resident companies with income subject to tax from sources within the Kingdom are chargeable to The applicable income tax rate is 20%, with the exception of tax rates for the Oil & Gas industries.
• Non-resident companies are taxed in Saudi Arabia in so far as they carry on an activity through a permanent establishment (PE) or derive an income in Saudi Taxable income of a permanent establishment (branch) is subject to tax at a rate of 20%.
• Capital gains on transferable securities are exempt from tax if the securities are acquired on or after 30 July 2004 and the transfer is performed in accordance with the provisions of the Saudi stock market Capital gains or losses on non- depreciable assets are taxable or deductible under the standard rules as the case may be.
• There is no tax on employment income in Saudi Arabia.
• The standard rate of Value Added Tax (VAT) is 15% and applies to all supplies of goods and services, except for specific items taxed at a 0% rate or those that are exempt.
• Excise Tax: tax levied on goods having an adverse impact on public health or the environment or on luxury goods in varying proportions, which include soft drinks, energy drinks, tobacco and its derivatives, sugar sweetened beverages and electronic devices and equipment used for smoking, as well as the liquids used in electronic devices and equipment used for smoking.
• A 5% RETT applies to the value of any real estate that is disposed of at the time of disposal. Real estate includes land constructions. Disposal includes sale, netting, gift, will, barter and leasing, financial leasing and transfer of shares in real estate companies.
• Zakat is payable by individual Saudis and other GCC Zakat is calculated at the rate of 2.5% of Zakat base for the respective Hijri year.

Key Tax Points

• The standard corporate income tax rate is 30%.
• VAT is levied at a standard rate of 18%.
• Losses may generally be carried forward for up to 3 Loss carry-back is not allowed.
• Dividends paid to non-resident companies are subject to a 10% final withholding tax on the gross amount.
• Interest derived by a non-resident company is subject to a final withholding tax on the gross amount ranging from 6% to 20%, depending on the underlying instrument.

• Royalties and technical assistance fees paid to non-resident companies are subject to a 20% final withholding tax rate on the gross amount (25% on 80% of the gross amount).
• Management fees, technical service fees and rental fees payments to non-resident companies are subject to a 20% effective withholding tax rate (25% on 80% of the gross amount).

Key Tax Points

• Corporate income tax is payable by a resident who is a legal entity established or has its place of effective management and control in the territory of the Republic of Non-residents are taxed only on their income sourced through a permanent establishment in Serbia. Corporate income tax is levied at a flat rate of 15%.
• The standard rate of Value Added Tax is 20%. A reduced rate of 10% applies to certain hospitality-related and other goods and services.

• A 20% withholding tax is applicable to various forms of payments to non-residents including: interest, dividends, royalties, rental fees, capital gains and certain service fees.

• Income tax is chargeable on all Serbian residents in respect of income generated in Serbia and other countries and non- residents on income sourced in the Republic of Serbia.

Key Tax Points

• For companies, the standard Business Tax rate is 15% on the first SCR 1,000,000 of taxable income and 25% on the
• There is no capital gains tax in the Seychelles.

Key Tax Points

• The standard corporate income tax rate is 25%.
• Dividends paid to a non-resident corporate shareholder are subject to a final 15% withholding tax.
• Interest paid to a non-resident company is subject to a final 15% withholding tax.
• Royalties paid to a non-resident company are subject to a final 15% withholding tax.
• Losses can be carried forward for up to ten years, subject to a limit of 50% of chargeable income for the respective year of assessment. Losses cannot be carried back.
• The standard GST rate is 15%.

Key Tax Points

• Resident and non-resident companies are liable for corporate income tax on income accruing in or derived from Singapore, or income received in Singapore from outside Singapore.

• Subject to certain conditions, foreign branch profits and certain foreign-sourced income such as dividend and service income remitted into Singapore by any resident companies are exempt from tax.
• Capital gains are not taxable, although transactions may be categorised as being trading in nature, and thus However, effective from 1 January 2024, a new section 10L introduced a tax on capital gains from the sale of foreign assets under certain circumstances.
• There are various tax exemptions and incentives to encourage trading and investment in Singapore.
• Individuals, regardless of residency, are subject to tax on income accruing in or derived from Foreign income received by residents and non-residents is generally not taxable, except under certain circumstances.
• Companies and individuals are taxed on a preceding year basis.
• Goods and Services Tax, also known as Value Added Tax, is levied on taxable goods and services in Singapore and on imports into the territory.

• Related party transactions are expected to be carried out at arm’s length while additional documentation is expected in situations of substantial related party There are no thin capitalisation nor controlled foreign company (CFC) provisions.
• Payments between resident companies do not attract withholding Interest, royalty and certain other payments by Singaporean companies to non-resident companies are, however, subject to withholding tax.

Key Tax Points

• Resident companies are subject to corporate income tax on their worldwide Non-residents are subject to corporate income tax only on income sourced in the Slovak Republic.
• The corporate income tax rate varies from 10% for companies with taxable income (revenues) not exceeding EUR 100,000 per tax period, 21% for companies with taxable income (revenues) between EUR 100,000 and EUR 5 million per tax period, to 24% for companies with taxable income exceeding EUR 5 million in the tax period.
• A preferential income tax regime for so called “micro-taxpayers” is also in place (i.e. taxpayers with annual taxable income not exceeding EUR 60,000).
• The standard VAT rate is 23% and two reduced VAT rates of 19% and 5% apply to specific supplies and E.g. 5% applies to medicines, basic food, books, accommodation services and restaurant services in relation to food, entrance to fitness centres, entrance to sport events). A reduced 5% VAT rate also applies to state-supported supplies of residential buildings or their renovation, including construction and assembly works on such buildings. A 19% VAT rate applies to the supply of selected foodstuffs and the supply of electricity, and also to the supply of non-alcoholic beverages (max. 0.5% alcohol volume) connected with restaurant and catering services.

• Capital gains are generally considered taxable income and taxed under the corporate income tax base at a 21% / 24% tax rate (or a reduced tax rate, if applicable). A specific tax treatment was introduced for state bonds with effect from 1 January 2025.
• There is no concept of group relief nor group tax regime for corporate income tax purposes.
• With regard to transfer pricing rules, the price and conditions agreed between related parties should reflect the price and conditions that would have been agreed between unrelated parties for the same or similar transactions and under the same or similar circumstances (i.e., fair market price/conditions). Should the price or conditions in transactions between related parties be different than prices/conditions applicable between unrelated parties, while this difference results in a decrease of the tax base or an increase in tax losses, the corporate income tax base must be adjusted by this This general rule applies to both domestic and foreign transactions.
• For corporate income tax purposes, dividends distributed to/received from entities that are tax residents of non-cooperative states are subject to a 35% tax rate. In all other cases, dividends are not subject to corporate income tax in Slovakia.
• For personal income tax purposes, dividends are subject to 7% withholding tax if an individual is tax resident in a cooperative state. Otherwise, dividends are subject to 35% withholding tax. Slovak tax residents (individuals) include dividend income into the specific tax base of the tax return, which is subject to a 7%/35% tax rate, depending on the source country (see point above). This rule applies to dividends distributed from profits generated for tax periods commencing on or after 1 January 2025. A 7% tax rate also applies to dividends distributed to / received by individuals who are tax residents of Slovakia or another cooperative state if dividends were derived from profits related to tax periods 2017-2023. The temporarily increased tax rate of 10%, which was in effect in 2024, will therefore only apply to dividends paid from profits reported for tax periods starting from 1 January 2024 and ending by 31 December 2024.
• Income sourced in the Slovak Republic (e.g., interest, royalties, technical and management fees, etc.) paid to non-resident taxpayers is basically subject to 19% withholding tax (this rate may be reduced by an applicable double tax treaty). A 35% tax rate applies if the recipient is a tax resident of a non-cooperative state or if the beneficial owner of the income is An annual property tax is levied on the owner or beneficial owner of a building, flat or land situated within the Slovak Republic. There is no inheritance tax, gift tax or real estate transfer tax.
• Personal income tax is payable by Slovak tax residents on their worldwide Non-residents are only subject to tax on Slovak-sourced income.
• In addition to personal income tax, employees are also subject to mandatory social and health insurance contributions and prepayments, all of which are withheld from their gross Employers are obliged to withhold the respective contributions and tax prepayments on behalf of their employees.
• Individuals can ask the tax authorities to assign 2% of their income tax liability to an eligible Slovak non-profit organisation (3% may be granted if specific conditions are met), while legal entities can grant 1% or 2% of their corporate income tax liability, depending on the circumstances. As of 2025 individuals can also assign 2% of their income tax liability to their parents.

Key Tax Points

• Resident companies are subject to corporate income tax on their worldwide Non-residents are taxable on Slovenian source income on particular types of income.
• Capital gains are included in a company’s profits subject to corporate income 50% of gains/losses derived from the disposal of shares are exempt subject to certain conditions.
• VAT is chargeable in accordance with the provisions of EU A standard rate of 22% applies to most transactions with a reduced rate of 9.5% available for some goods and services while a 5% VAT rate is applied to books and magazines.
• Relief for double taxation is provided by means of credit for overseas tax suffered on overseas The credit is the lower of the foreign tax paid and the Slovenian tax on the income concerned.

• Withholding taxes are due in respect of various types of payments to residents and non-residents. Withholding taxes do not apply to dividends distributed to legal persons where a common system of taxation applies or in respect of dividends and similar income distributed through a business unit of a non-resident located in Slovenia.
• Resident individuals are subject to personal income tax on their worldwide Non-residents are taxable on Slovenian source income.

Key Tax Points For Somalia

• Company tax is based on computed tax profits at 9% to 30%, dependent on the level of
• Sales tax is levied at a rate of 5%.
• Employment income is taxed at between 0% to 18% depending on the basic salary.

Key Tax Points

• Resident companies are generally taxed on their worldwide Non-resident companies are taxed on their South African sourced income.

• Dividends paid or that become payable by a South African company to a shareholder are subject to a 20% withholding tax. Withholding tax is not levied on dividends paid to another South African company and dividends paid by headquarter companies.
• Companies are subject to tax for years of assessment ending on or after 31 March 2026 at the corporate tax rate of 27% (previously 28%).

Key Tax Points

• Corporate Income Tax: Domestic corporations are taxed on their worldwide income, whereas foreign corporations are taxed only on their Korean-source income. The corporate income tax rates vary from 9.9% (including local income tax) to 26.4% (including local income tax) depending on the level of total taxable income for the year.
• Value Added Tax: VAT is imposed at a rate of 10% on supplies of goods and However, zero-rated VAT or exemption is applied to certain supply of goods and services.

• Individual Income Tax: Any person domiciled in Korea or having resided in Korea for 183 days or longer is subject to individual income tax on his/her worldwide income (i.e. Korean-sourced income and foreign-sourced income). Individuals are taxed at progressive rates from 6% (including local income tax) to 49.5% (including local income tax) depending on their total taxable income for the year.
• Withholding Tax: Taxes are required to be withheld at rates ranging from 2% to 20%, from certain cross-border payments made to non-resident individuals or corporations without a permanent establishment in Korea, unless exempted or reduced under a relevant double tax treaty.

Key Tax Points

• Businesses liable for Business Profit Tax (BPT) are subject to BPT on taxable or net profit at 30% regardless of the size of the business.

• Capital gains are deemed to be business income subject to the aforementioned applicable corporate tax rate.
• Sales tax applies to the import of goods into South Sudan, production of goods in South Sudan and provision of hospitality services in hotels, bars and restaurants at a rate of 20%.
• Transactions between related parties are required to be at arm’s length.
• From an accounting perspective, financial statements must be presented in accordance with applicable relevant laws and International Financial Reporting Standards.

Key Tax Points

• A Spanish resident company is liable for corporation tax on all sources of income and capital gains, wherever A non- resident company is taxed on income and gains of a branch carrying on a trade in Spain. Foreign branch profits of a Spanish company are liable to Spanish tax.
• Trading profits, other income and capital gains are liable to corporation tax at the rate of 25%.
• Capital gains are taxed as ordinary income.
• The transfer of real estate is generally subject to VAT at 21%. This is reduced to 10% for private residential If the transferor is not within the VAT system, transfer tax at 6% is applicable.
• Transfer tax is payable on the transfer of movable property, at a rate of 4% of the value.
• VAT is levied on the supply of taxable goods and The standard VAT rate is 21% while a 10% reduced rate is in place and a super-reduced rate of 4% on certain basic goods and services. Exports and international services provided to EU and non-EU countries are exempt from VAT.

• Dividends and interest are generally paid subject to a withholding tax of 19% at source, although this is normally reduced or eliminated by a double tax treaty.

• Foreign taxes may be credited against Spanish corporation tax, whether or not a treaty exists with the foreign country.
• Spanish-resident individuals are liable for personal tax on their worldwide income; non-residents are only liable for tax on Spanish-sourced income.
• Resident individuals are subject to net wealth tax in respect of their worldwide The various autonomous governments can establish different reductions.
• There is an inheritance tax charge on a recipient of property passing by gift or death.

Key Tax Points

• As from 1 January 2021 corporate tax is levied at a rate of 6% (previously at 21.4%) on the worldwide income of companies’ resident in Sweden and also on profits which arise from activities carried out in Sweden through a branch or an agency.
• In general, output VAT is levied on all domestic sales, but not on export or EU sales.
• Stamp duty of 25% is levied on real property, 1.5% if the buyer is an individual.
• Dividends received from other Swedish companies are exempt from tax if the dividends derive from business-related holdings.
• Controlled foreign corporation (CFC) legislation exists to ensure that profits originating from low tax jurisdictions are included in the controlling Swedish company’s taxable income.

• Double taxation is generally relieved by providing credits for the foreign tax However, some older Double Taxation Conventions exempt foreign income from Swedish tax if it is taxed abroad.
• Transactions at a non-arm’s length price are covered by transfer pricing rules, which allow the tax authorities to make an adjustment to impose arm’s length prices where profits have been shifted to a company not subject to Swedish tax.
• There are no withholding taxes on interest and royalties paid from Sweden to non-residents. Dividends paid to a non-resident shareholder are subject to a 30% withholding tax that may be reduced by a double tax treaty.
• A participation exemption applies for dividends received on shares held for business reasons and on qualifying holdings via Shares in Swedish corporations can qualify as shares held for business reasons. Unquoted/unlisted shares will always be considered as held for business reasons. Quoted/listed shares are considered held for business reasons if the company has a holding corresponding to at least 10% of the voting rights or the shares are held in the course of the business. An additional condition regarding quoted/listed shares is that the shares must be held for a period of at least one year. Subject to certain conditions, a tax exemption also applies to shares in foreign companies.

• Residents must pay tax on their worldwide income and capital Non-residents are subject to tax only on income from sources in Sweden.

• Capital gains derived by a company are taxed as part of its normal business income although there are special rules for the disposal of Gains on the disposal of shares in resident and non-resident companies are exempt from tax if they constitute a business-related holding. This generally applies to unquoted shares and also to quoted shares held for at least the year prior to the date of disposal and which represent at least 10% of the company’s voting rights or considered necessary for the business conducted by the shareholding company or any of its affiliates.

• Pillar Two implementation. The global minimum tax under the OECD Global Anti-Base Erosion (GloBE) rules and the EU Directive 2022/2523 of 14 December 2022 has been transposed into Swedish law and entered into force on 1 January 2024. The Swedish rules contain a Qualified Domestic Minimum Top-Up Tax (QDMTT), an Income Inclusion Rule (IIR), and an Undertaxed Profits Rule (UTPR). On 2 December 2024, the Swedish Parliament adopted the proposal from the government on supplementary provisions meaning that the Swedish QDMTT meets the conditions for benefitting from another country’s QDMTT safe harbour rules. Among other changes are modifications to the foreign tax credit act that enable offsetting foreign QDMTTs against taxes due under the Swedish CFC The amendments entered into force on 1 January 2025 and the legislative changes apply for the first time for tax years beginning immediately after 31 December 2024. However, the reporting entity may request that all or certain of the provisions be applied already for tax years beginning immediately after 31 December 2023, i.e. at the same time as the provisions already in force.

Key Tax Points

• In Switzerland, federal law and 26 different cantonal tax laws govern taxes.
• Corporate income tax is payable by Swiss resident companies on corporate net profit.
• Foreign branch income of a Swiss corporation is exempt from Swiss taxation.
• Capital gains on real estate (if a part of business assets) for direct federal tax and several cantonal tax purposes are aggregated with and taxed as part of ordinary income.
• VAT is charged on the domestic delivery of goods and rendering of services as well as on the importation of goods and services into Switzerland. The standard VAT rate is 8.1%. Specific lower rates (2.6% or 3.8%) apply to various services and goods, subject to certain exemptions.
• Dividends paid from Swiss capital companies to Swiss residents and non-residents are subject to 35% withholding Shareholders resident abroad may obtain relief under the appropriate double taxation treaty.
• There is no withholding tax on royalties or interest (some exceptions apply).
• Deemed distributions may arise to the extent that prices between related parties exceed those on at arm’s-length Withholding tax may be applied to the deemed distributions.
• A Swiss resident individual is subject to Swiss federal, cantonal and communal taxes on his worldwide income and net wealth, with the exception of income from investments in foreign permanent establishments and real estate situated Basically, foreigners are regarded as residents from the date of registration.
• Net wealth taxes, inheritance and gift taxes are levied by most cantons, but they are not levied at federal level.

Key Tax Points

• Domestic entities are taxed on a worldwide basis, while other entities pay tax only on income sourced in Where a non- resident company has Taiwan-sourced income but no place of business or agent in Taiwan, the company’s income is taxed at source under the withholding tax regime.
• Taiwan taxes all profit-seeking enterprises operating in Taiwan with total taxable income over NTD 120,001 at 20% effective 1 January 2018 (but the tax may not exceed 50% of the portion of taxable income over NTD 120,000).
• Profits that are earned in a year but not distributed by end of the following year are subject to 5% advance tax.
• All gains and losses on the disposal of capital assets are taxable as current year income or deductible as expenses with the exception of marketable securities and futures.
• 5% value-added business tax is applied to business entities in most industries under the VAT Export sales and export- related services, however, are subject to a zero tax rate. Financial institutions are subject to non-value-added business tax.
• There are no local income taxes.
• Foreign tax suffered on overseas income is creditable against Taiwanese tax subject to a limit of Taiwanese tax payable on such income. Any unused tax credits may not be carried back or forward to other years.

• Domestic corporations paying certain types of income are required to withhold tax between 5% and 21%.
• Individuals are only subject to income tax on Taiwan source income with income derived from foreign sources being exempt from income Residents, both Taiwanese and foreign nationals, pay tax on net consolidated income calculated as the total income received from all Taiwan sources less exemptions and deductions.
• Alternative Minimum Tax: if the amount of regular income tax for a company or an individual is less than the amount of Income Base Tax (IBT), the total tax payable is the amount of the Income Base Tax (IBT).

Key Tax Points

• Gross income reduced by the amount of deductions (expenditures) provided by the Tax Code of Tajikistan is subject to corporate income tax at the level of residents.

• Gross income is subject to corporate income tax at the level of a non-resident in case of receiving Tajikistan-source income and not linked with its permanent establishment.
• Effective from 1 January 2022, a new Tax Code has been introduced, replacing the Tax Code of The following corporate income tax rates apply:
  • for enterprises producing goods, a rate of 13% applies;
  • for financial institutions and mobile companies, a rate of 20% applies;
  • for extraction and processing of natural resources and other activities, a rate of 18%
• The VAT rate is 14% on taxable turnover, except for the export of goods and certain reduced tax rates, and 14% on taxable imports. Export transactions of inventories are taxed at a zero rate.
• Capital gains from business assets are taxed at the normal tax Capital gains derived by a shareholder of the corporation when selling his shares are not subject to tax.

• Dividends paid to residents and non-residents are subject to a 12% income tax.
• Income under the simplified regime for individuals registered as a private entrepreneur and legal entities is taxed on net income received in cash at a rate of 6%.
• The taxable income of individuals who are residents of Tajikistan is taxed at a rate of 12% on income from their primary place of employment, exceeding the personal allowance, and at a rate of 15% if the employment is not their primary place of In addition, a social tax of 2% is withheld at the level of an insured person while the social tax on an individual’s income paid by the company is 20%.
• Assets handed as a gift are Inherited assets are not taxed.
• Other taxes include primary aluminium sales tax, annual property tax, vehicle tax and natural resources tax.
• The taxable income of a non-resident individual from employment received from sources in Tajikistan is taxed at a rate of 20%.
• The taxable income of a legal entity is taxed at the following rates:
  • for activities for the production of goods – 13%;
  • for the activities of credit and financial organisations and mobile companies – 20%;
  • for the extraction and processing of natural resources, as well as for all other types of activity – 18%.

Key Tax Points

• Corporate tax is payable by Tanzanian companies on their worldwide taxable income at the rate of 30%.
• Value Added Tax is generally charged at the standard rate of 18% on any supply of goods or services in mainland Tanzania.
• The maximum employment tax rate is 30%.
• There are several sources of income that are subject to withholding taxes, generally at rates from 2% to 15%.
• Tax refunds are supposed to be claimed from TRA within three years from the date of overpayment.

Key Tax Points

• The tax residency of a company is determined by the place where the company is incorporated, i.e., Thai tax resident companies are those incorporated in Companies incorporated outside Thailand are non-resident companies.
• A resident company is subject to Corporate Income Tax (CIT) on its worldwide income and Non-resident companies are subject to CIT on their domestic sourced income and gains. The current CIT rate is 20%.
• The tax residency of an individual is determined by the period in which the individual is present in Thailand. Resident individuals are those who are present in Thailand for at least 180 days in a calendar Resident individuals are subject to income tax on Thai sourced income and overseas income if remitted to Thailand in any calendar year in which it is derived or earned after 2023. Non-resident individuals are subject to tax on income from sources in Thailand. Personal income tax is calculated using progressive tax rates from 0% to 35%.
• Thailand relies on a self-assessment system and capital gains are treated as part of normal assessable income.
• A 10% profit remittance tax is imposed on profits remitted out of Thailand by Thai branches of foreign companies.
• Thailand has many double tax treaties (DTTs), currently with 61 countries, which provide for the elimination of double taxation using credit or exemption After joining the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), Thailand signed the Multilateral Convention on Mutual Administrative Assistance on Tax Matters to provide mutual assistance to other members in tax matter requests, including exchange of information on request, spontaneous exchange, automatic exchange, tax examination abroad, simultaneous tax examinations, and assistance in tax collection. Furthermore, Thailand has agreed to the OECD’s 2021 Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalization of the Economy.
• Under a relevant DTT, credit relief is provided for overseas taxes against taxation in Thailand up to a maximum of the Thai tax on the overseas income concerned so as to mitigate double taxation.
• With respect to a country that does not have a DTT with Thailand, credit relief is provided for overseas taxes against taxation in Thailand up to a maximum of the Thai tax on the overseas income concerned in order to mitigate double taxation.
• Thai domestic tax laws do not include provisions on Controlled Foreign Corporations (CFCs) or thin capitalisation.
• Value Added Tax (VAT) is levied on the supply of goods and provision of services in Thailand and on the importation of goods into A service performed abroad but made use of in Thailand is also deemed to be a provision of services in Thailand. The current VAT rate is 7%. Certain supplies may be zero-rated or exempt.
• The submission of VAT returns is required in Thailand by overseas digital service providers or operators of electronic platforms having annual revenue in excess of THB 1.8 million. No input VAT is allowed at the level of overseas digital service providers with respect to the submission and payment of VAT.
• Individuals or companies with ownership and/or usage rights over land and buildings (including condominium units) are subject to pay an annual land and building Land and building tax rates vary based on the purposes of use of land and buildings.
• Specific Business Tax (SBT) is imposed on certain transactions that are not subject to VAT (basically financial transactions, g., lending money, and the sale of immovable property) from 2.5% to 3% plus a local tax levied at 10% of the SBT rate resulting in an effective SBT rate of 2.75% to 3.3%.
• Stamp Duty is payable on certain types of instruments from THB 1 Baht to THB 200 per THB 1,000 of document value or a fixed amount specified by the Thai Revenue Code (TRC).
• Thailand is a signatory to the OECD’s Multilateral Instrument (‘MLI’) which implements tax treaty related measures to certain DTTs to prevent base erosion and profit shifting. The convention impacts the 58 tax treaties Thailand has entered into and applies to relevant withholding taxes and taxable periods with effect from 1 January 2023.

Key Tax Points

• The corporate income tax rate is 27%.
• A 1% minimum lump-sum minimum tax applies on total turnover ‒ exclusive of VAT ‒ realised during the last financial year. It is paid by companies with losses or zero results or when the corporation tax is lower than the minimum lump-sum The amount cannot be lower than FCFA 20,000 for taxpayers subject to the normal tax regime.
• VAT is levied at a standard rate of 18%.
• Ordinary losses incurred during a tax year are considered deductible expenses of the following tax year up to 50% of the net profits of that year. The remaining losses may be carried forward indefinitely. Loss carry-back is not allowed.
• Dividends paid to non-resident companies are subject to a 13% final withholding tax on the gross amount, subject to the application of a double tax A reduced 7% withholding tax rate applies at the level of companies to dividends distributed by companies listed on a stock exchange within the WAEMU approved by the CREPMF. A reduced 3% withholding tax rate applies at the level of natural persons for distributions by listed companies.
• Interest derived by a non-resident company is subject to a 13% final withholding tax on the gross amount, subject to the application of a double tax treaty.
• Royalties and technical assistance fees paid to non-resident companies are subject to a 20% final withholding tax rate on the gross amount, subject to the application of a double tax treaty.
• Management fees and technical service fees paid to non-resident companies are subject to a 20% withholding tax rate.

Key Tax Points

• Resident companies are liable to corporation tax on their worldwide Other companies are taxed on their income from sources generated within Trinidad and Tobago. The standard rate of corporation tax is 25%. However, companies earning in excess of TTD 1 million will be liable to a rate of 30%. This can be varied if there is a double tax treaty.
• Although the basic rate of VAT is 5%, some items such as exports and some basic foodstuffs are charged at the rate of 0% and some services such as real estate transactions as well as financial and insurance services are VAT exempt.
• Stamp Duty is levied on several documents, and also on transfers of commercial or residential real estate charged at rates of 0%, 2%, 5%, 7%, 5% and 10%. Stamp duty on the purchase price of houses for first-time house owners is 0% for all properties valued under TTD 2 million.
• Certain entities are not liable to taxation, by virtue of their status as a not-for-profit or religious organisation or those governed by specific legislations that grant them tax-free status.

Key Tax Points

• Companies are generally subject to corporate income tax at the rate of 20% from 2025; 40% for banks and (re)insurance companies, 35% for other financial institutions, telecommunications operators, hydrocarbon companies, hydrocarbon service companies and companies exploiting a foreign brand (reduced to 20% for certain activities if the company lists 30% of its share capital before 31 December 2025);10% for farming and fishing activities.
• VAT is charged at 7% (IT services, hotels and restaurant activities, and equipment, medical activities), 13% (raw materials, craft industry products and canned food) or 19% (operations related to services and goods not subject to another rate).
• Inherited property and gifts are subject to tax at rates varying from 5% to 35%, depending on the closeness of relation.
• For most categories of income, the payer of income has to withhold tax at source, file a tax return and submit the amount of tax withheld to the Treasury.

Key Tax Points

• Corporations in Türkiye can be regarded as either limited or full Full taxpayers are liable for tax on their worldwide income. Limited taxpayers are subject to tax on income derived in Türkiye.
• A foreign corporation is regarded as a limited taxpayer in Türkiye, and is taxable on its Turkish-sourced income only.
• Capital gains are generally treated as part of ordinary corporate income.
• VAT is levied on all goods and services supplied within the scope of commercial, industrial, agricultural and independent professional activities and on the importation of goods and services.
• The withholding tax rate on dividend payments has been increased to 15% as of 22 December Previously, the tax rate was 10%.

The repatriation of after-tax profits of branches to overseas headquarters is also subject to withholding tax (as is the case with profit distributions by companies). The recent decision to increase the withholding tax rate to 15% also applies to such repatriation of branch profits.

No withholding tax is imposed on dividends paid to a resident company and hence the recent decision does not have an impact on profit distributions from a resident company to another resident company.

• Business-related interest may be deducted during an operational period but must be capitalized if it is related to acquiring a fixed Financial expenses for the first year only are added to the cost. The interest can be capitalised or recognised as a financial expense in subsequent years.
• Controlled foreign company (CFC) regulations are in place in Türkiye. They apply where a resident company has at least a 50% interest in a non-resident company subject to certain other conditions as well.
• Transfer pricing rules apply to resident companies with transactions with related parties, whether resident or not in Türkiye.

Individuals residing in Türkiye are subject to income tax on their worldwide income while non-resident individuals are subject to income tax only on income earned in Türkiye

Key Tax Points

• Resident companies are taxable on their worldwide income and gains whereas non-residents are subject to tax on income sourced in Uganda.

• The standard rate of corporate income tax applicable to resident and non-resident companies is 30%, although special rates apply to small businesses and mining companies.

• Capital gains and losses only arise in respect of non-depreciable assets owned by a Gains are added to and taxed along with ordinary income.
• A tax at 15% is charged on repatriated profits of overseas companies with branches in Uganda.
• VAT is charged at a standard rate of 18% but some supplies are zero rated or exempt.
• Dividends are generally subject to withholding tax where paid to residents or non-residents at a rate of 15% (or 10% where the payer is listed on the Ugandan Stock Exchange).
• Other payments for goods and services are subject to withholding tax with different rates in some cases depending on whether the recipient is resident in Uganda.

• Income tax is levied on the worldwide income of resident individuals (a foreign tax credit is granted for foreign sourced income not exceeding the appropriate Uganda income tax payable) and on the income of non-resident individuals sourced from Uganda.
• A Tax Procedure Code Act, assented to on 19 October 2014, came into force with effect from 1 July 2016, to provide a code to regulate the procedures for administration, to harmonize and to consolidate tax procedures.

Key Tax Points

• Ukraine has been under martial law since 24 February 2022 as a result of which all tax and other laws are adhered to in compliance with martial law regulations.
• The Tax Code of Ukraine determines taxable profits as net profits before tax as per the accounting records, either Ukrainian statutory or International Financial Reporting Standards (IFRS) and adjusted for “tax differences”. Companies with total revenue from all types of business activities not exceeding UAH 40 million are allowed to define taxable profits without taking “tax differences” into consideration.
• Companies in Ukraine generally pay corporate income tax (CIT) at a flat rate of 18%. Special tax rates apply to certain types of In particular, a CIT rate of 25% is applied to banks since 2024. Additional rates of 0% or 3% apply to qualified insurance activities. Income (profit) of a non-resident derived from Ukrainian sources is taxable at a rate of 0%, 4%, 5%, 6%, 12%, 15% or 18%.
• Value Added Tax (VAT) is currently levied at a rate of 20% on the taxable value of domestic supplies, services and imported goods. The rate on exported goods is 0%. The VAT rate on supply of medicines and medical devices is 7%. Certain VAT benefits introduced further to martial law are also in place.
• Ukrainian tax residents (individuals) are subject to personal income tax (PIT) on their worldwide income, whereas non- residents are only subject to taxation on the Ukrainian-sourced portion of their The tax rate varies from 0% to 18% of the tax base and depends on the type of income. The standard applicable rate for PIT is 18%.
• All types of income subject to PIT are also subject to military The rates of the military duty range from 1% to 10% of the taxable income (new rates were introduced in 2025).

• Lower tax rates are applied to City residents: CIT of 9% or 18% for companies, and PIT of 5% for individuals.
• When paying wages (or similar payments) the source of payment needs to accrue for and transfer a single contribution for mandatory state social insurance (SC) to the The standard rate is set at 22%, while a reduced rate may apply for some categories of individuals.
• Legal entities and individuals (including non-residents) are subject to property tax. Property tax is divided into real estate tax, other than land plot, land tax and vehicle The real estate tax rates are set by local self-government bodies at a percentage (not exceeding 1.5%) of minimum salary, established by law as of 1st January of the tax (reporting) year per 1 sq. metre of tax base. The land tax rate is also established at a percentage by local self-government bodies. However, the tax base is the monetary valuation of the land plot and the tax rate cannot exceed 3%.

• Controlled Foreign Companies (CFC) rules were recently introduced in Ukraine. Under the CFC rules income of a foreign company owned or controlled by a Ukrainian tax resident (either an individual or a legal entity) may be taxed in Ukraine in certain circumstances. The first CFC reports were submitted in 2024 in Ukraine.

Key Tax Points

• The Federal Tax Authority (‘FTA’) of the UAE released the Corporate Tax Decree Law, e. ‘Federal Decree-Law No. 47 of 2022 – Taxation of Corporations and Businesses’ (‘Corporate Tax Decree Law’/ ‘CT Decree law) on 9 December 2022, which applies to tax periods/financial years commencing on or after 1 June 2023.
• On 24 November 2023, the FTA published Federal Decree Law (60) of 2023, amending specific provisions of Federal Decree Law No. (47) of 2022 on the Taxation of Corporations and Businesses (CT Law)
• The CT Decree Law is broadly in line with internationally accepted taxation It provides a broad framework of Corporate Tax (‘CT’). There have been several Cabinet and Ministerial decisions issued for further guidance in respect of certain provisions mentioned in the law.
• The FTA issued directions for time bound CT registration which is linked to the issue date of the licence of an entity and a timeline of 3 months from the issuance of the decision for entities who do not have an existing licence.
• The CT Decree law includes Transfer pricing provisions which are applicable for prescribed taxpayers having transactions with related parties/connected persons. It also states that the opening balance sheet for the first tax period for UAE CT purposes needs to be prepared taking into consideration the arm’s-length principle.
• The CT Decree law includes General Anti Abuse Rule (‘GAAR’) It states that GAAR will be applicable for transactions or arrangements entered into on or after the date the CT Decree Law is published in the Official Gazette.
• The FTA further issued various guides on the provisions mentioned in the law, g. Guide on small business relief, taxation of partnership firms registration of persons, exempt income, transfer pricing, etc.
• The withholding tax rate on certain UAE sourced income and other specified income of non-residents is 0% or any rate specified by Cabinet decision.
• Entities incorporated in a qualifying free zone and having qualifying income are eligible to benefit from a 0% Corporate Tax rate on the qualifying income, subject to certain conditions.
• Additionally, the tax decrees issued by the Emirates impose income tax at varying rates on taxable income of ‘bodies corporate, wheresoever incorporated’, but the enforcement is generally limited to foreign oil exporting companies and foreign banks.
• Corporates, which are subject to Emirate level taxation, are not covered under the CT decree law, except for banking sector
• As per Dubai Emirate Law 1 of 2024, a tax rate of 20% has been introduced on the annual taxable income of a foreign bank. The foreign bank will be provided with the credit of the corporate tax paid under CT Decree Law.
• 5% VAT is applicable on supply of most goods and services.
• The UAE levies excise tax on tobacco and tobacco products, carbonated drinks, energy drinks, sweetened drinks, electronic smoking devices and tools as well as liquids used in such devices and tools.
• 100% foreign ownership of companies in the UAE mainland is now permitted in the majority of sectors except for activities with a strategic impact (e.g., security and defence activities, activities that are military in nature, banking, exchange companies, financing companies, insurance activities, currency printing, telecommunications, Hajj and Umrah services, Holy Quran memorisation centres and services associated with fisheries), subject to certain conditions.
• Long-term visas for 5 years or 10 years are available for specified categories of persons, which shall be renewed automatically.
• The UAE has entered into and concluded double tax treaties (“DTT”) with over 140 countries/jurisdictions.
• As part of the Organisation for Economic Co-operation and Development’s (“OECD”) Base Erosion and Profit Shifting (“BEPS”)

Inclusive Framework, the UAE became a signatory to the OECD’s BEPS Multilateral Convention (“MLI”) in 2018 and deposited the instrument of ratification in May 2019. The UAE’s DTTs with member countries/jurisdictions may therefore stand modified.

• UAE DTTs with the Democratic Republic of the Congo, Gabon and Zambia entered into force during the year 2023.In line with BEPS Action 5 on Countering Harmful Tax Practices, the UAE has introduced Economic Substance Regulations (“ESR”) with effect from April 2019. These regulations require all in-scope UAE entities that carry out prescribed Relevant Activities and earn income out of such Relevant Activities to have economic substance in the UAE commensurate with the level of activities they As per Decision No. (98) of 2024, UAE ESR will no longer be applicable for the financial year started on or after 1 January 2023.
• In line with BEPS Action 13 on three-tier Transfer Pricing Documentation, the UAE has issued Country-by-Country Report (“CBCR”) Regulations with effect from January 2019 applicable only to Multinational Enterprises (“MNEs”) headquartered in the UAE.
• Recently, the UAE has issued Cabinet Decision No (142) of 2024 on Domestic Minimum Top-up Tax (“DMTT”) in the UAE in line with OECD guidelines under BEPS 0 Pillar 2. As per this decision, DMTT will apply to Multinational Enterprises (“MNEs”) that are within the scope of Pillar Two based on the OECD Global Anti-Base Erosion (“GloBE”) Model Rules, and will be imposed in cases where the MNE’s effective tax rate (“ETR”) in the UAE is below 15%. The DMTT is effective for financial years starting on or after 1 January 2025.

Key Tax Points

• A company resident in the UK is generally chargeable to Corporation Tax on all its sources of income and capital gains, wherever Companies with overseas permanent establishments may however make an election to exempt profits and losses from those permanent establishments from UK tax, if conditions are met.
• From 6 April 2020, a company not resident in the UK but receiving rental income from UK property is liable to UK corporation tax. Previously, such companies were subject to income This represents a significant change as Corporation Tax rules now apply in determining taxable profits.
• Dividends received by UK companies from both UK and non-UK companies are generally exempt from Corporation Tax if conditions are met. These conditions are stricter for smaller recipient companies.
• Where income or gains arising overseas are taxable on a UK resident company due to the conditions for exemption not being met, double taxation relief is generally available in respect of foreign tax suffered.
• Non-resident companies are liable to Corporation Tax if they carry on a trade in the UK through a permanent establishment in the UK. Capital gains arising on a non-resident company in respect of the sale of assets used in, or for the purposes of a trade carried on through a UK permanent establishment are also subject to Corporation Tax.
• Controlled foreign companies (CFC) legislation is in place to ensure that profits diverted from the UK to subsidiaries resident in low tax jurisdictions are included in a controlling UK company’s taxable Exemptions exist and only profits that pass through a gateway test are subject to Corporation Tax.
• Transfer Pricing rules impute arm’s-length pricing to transactions between connected parties whether located overseas or in the UK. For Small or Medium-sized entities (SMEs) the application of the rules is generally restricted to transactions with countries with which the UK does not have a ‘full’ double tax Anti-profit fragmentation rules were introduced from 1 April 2019 to prevent profit diversion and applies to UK resident companies, partnership and individual of all sizes.
• With effect from 1 April 2023. Multinational Enterprises (MNEs) with consolidated turnover of EUR 750 million or more, operating in the UK, will be required to keep and maintain a Master file and Local File in accordance with the OECD Transfer Pricing Guidelines.
• The ‘Diverted Profits Tax’ came into force in April 2015. This imputes a tax charge of 31% on profits ‘artificially diverted’ from the UK through transactions which have no economic substance, where the arrangements are not otherwise caught by CFC or Transfer Pricing rules. This tax is not covered by UK Tax treaties, the charge may not be creditable for overseas tax purposes.
• Country-by-Country reporting regulations apply to multi-national groups with a UK parent company and turnover of EUR 750 million or more. Such entities must provide HMRC with an annual report which discloses certain financial and fiscal information for each country in which the group carries on its business.
• UK Companies, UK partnerships, UK groups or UK sub-groups with turnover of GBP 200 million or more or a balance sheet total over GBP 2 billion in the previous tax year, are required to publish their tax strategy on the internet. If the UK company or group is part of a multinational group that meets the threshold for Country-by-Country Reporting, then that UK company or group will also need to publish a strategy – the strategy should cover matters relevant to UK tax.

• Companies incorporated in the UK with, either alone or when its results are aggregated with other UK companies in the same group, a turnover of more than GBP 200 million and/or a balance sheet total of more than GBP 2 billion must comply with the Senior Accounting Officer regime. Qualifying companies are required to appoint a Senior Accounting Officer (SAO) and notify HMRC that they have done so. The SAO is responsible for taking reasonable steps to ensure that a company has appropriate tax accounting arrangements and certifying this to The SAO can be held personally liable to a penalty in the event there is a failure in this duty.
• UK companies/groups with net UK interest expense above GBP 2 million are required to apply complex rules to establish the corporate tax deductibility of their interest The default test is known as the ‘fixed ratio test’, this limits the allowable net UK interest expense to 30% of a group’s UK EBITDA. Alternatively, a group can elect to apply the ‘group ratio test’, which limits the allowable net UK interest expense to the ratio of external net interest to EBITDA for the worldwide group.
• Companies are generally able to use carried forward losses arising from 1 April 2017 against profits from other income streams or against profits generated by other group companies. Above a group de minimis of GBP 5 million, the amount of carried forward losses (of whatever description) that can be offset will be restricted to 50% of the amount of taxable profits.
• VAT is charged on the supply of most goods and services in the UK and on the importation of goods from outside of the UK.
• The VAT registration threshold was raised to GBP 90,000 from 1 April 2024 (from GBP 85,000). There is a nil registration threshold for businesses making taxable supplies in the UK, where they have no UK establishment.

• Income Tax at 20% must be withheld from payments of interest or royalties, although since April 2016 banks are no longer required to deduct Income Tax from certain payments of interest, principally where the recipient is a UK resident Double tax treaties can reduce or remove this charge in many cases, although this is subject to a successful claim for treaty benefits to apply in respect of interest payments prior to the payment being made. There is no withholding tax on dividends.
• Resident and UK domiciled individuals are subject to Income Tax on their worldwide income as it Non-residents are normally only subject to Income Tax on income arising in the UK.

• UK resident individuals who are non-UK domiciled can choose to be taxed only on their income and capital gains arising in the UK, together with income and gains remitted to the UK from overseas in a given tax year (the remittance basis). However, non- domiciled individuals who are long term residents are required to pay an annual charge to qualify for this treatment. From 6 April 2017 new rules are also in existence to treat certain individuals as UK domiciled for income tax and capital gains tax purposes. These include non-domiciled individuals born in the UK with a UK domicile and who have since taken a non-domicile status but are UK resident for the relevant tax year (referred to as formerly domiciled residents), as well as non-domiciled individuals who have been UK resident for at least 15 of the previous 20 tax years.

• Non-domiciled individuals who come to work in the UK, and who were not resident in the UK for any of the previous three tax years, can claim overseas work day relief for the first three tax years following arrival in the UK.
• A UK domiciled or deemed domiciled individual is potentially subject to Inheritance Tax on the transfer of any property owned by him, whilst a non-UK domiciled individual may only be subject to Inheritance Tax on the transfer of property situated in the UK. Inheritance Tax is a combination of gift and death tax. For UK inheritance tax purposes an individual will be treated as UK domiciled if they have been UK domiciled within the three years preceding the relevant date, or from 6 April 2017 they have been resident in the UK for at least 15 out of the previous 20 years and at least one of the four years ending with the relevant year, or from 6 April 2017 the individual returns to the UK to become UK resident, having had a UK domicile at birth but later emigrated and acquired a foreign domicile and is UK resident for the relevant year as well as at least one of the previous two tax years.
• From 6 April 2015, non-residents owning UK residential property are subject to Capital Gains Tax in respect of gains arising on a disposal of that property. From 6 April 2019, non-residents have also been liable to Capital Gains Tax on the sale of non- residential UK property as well as certain indirectly held interests in UK property. In most cases, only increases in value from either April 2015 or April 2019 (as appropriate) will be subject to charge. Non-residents (other than companies) are required to complete and lodge a Property Capital Gains Tax return for a disposal of an interest in UK property within 60 days of disposal (30 days if completion was before 27 October 2021). Any Capital Gains Tax is also due within that period.
• From 6 April 2020, UK residents (except companies) also need to file a Property Capital Gains tax return within 60 days of completion of a disposal of UK residential property if there is a capital gains tax liability (30 days if completion was before 27 October 2021). The Capital Gains Tax also needs to be paid within that period.
• UK residential property owned by non-natural persons (e.g. companies) is subject to an annual tax (Annual Tax on Enveloped Dwellings) but there are reliefs where the property is used in certain property businesses, including ATED compliance obligations arise in respect of properties valued at GBP 500,000 or more.
• UK resident trusts are liable to UK tax on worldwide income and Non- resident trusts are liable to UK tax only on UK income and disposals of UK land/property (the latter with a 60-day reporting requirement).
• Anti-avoidance legislation exists to attribute the income and gains of offshore trusts and companies to UK residents who set up such structures and their UK resident beneficiaries.
• Trusts are subject to their own Inheritance Tax regime on worldwide However, foreign assets settled by a non-UK domiciled person (who was also not deemed domiciled) are excluded.

• Devolved taxes – with effect from 1 April 2018 the Scottish Government introduced new tax rates applicable to employment, trading, pension and rental income for Scottish resident taxpayers. Land and Buildings Transaction Tax applies to land and property located in Scotland – See I There are separate Land and Buildings Transaction Tax and Landfill Tax regimes in Scotland. Separate devolved powers apply for Northern Ireland, see H below.
• HMRC wish to become one of the most digitally advanced tax administrations in the world. From 1 April 2019 HMRC have required most businesses, self-employed people and landlords to maintain digital tax accounts and submit quarterly digital returns where VAT registered. A consultation was launched March 2021 in to digitalising the corporation tax administrative system.

• From 6 April 2021, any medium or large company (any business which breaches two of the following conditions – turnover over GBP 10.2 million, balance sheet value over GBP 5.2 million, or over 50 employees) engaging contractors through an intermediary such as another company, partnership or employment business is required to undertake a formal assessment of the contractor’s employment tax status which includes the issue of a formal Status Determination Statement to the contractor and to the fee-payer if this is not the engager. Where the Statement indicates the contractor is a deemed employee for tax purposes, the engager (or fee-payer where applicable) is required to withhold PAYE and National Insurance Contributions prior to paying the contractor and to remit these deductions to HMRC in accordance with standard payroll There is additional employer National Insurance Contributions payable to HMRC.

Key Tax Points

• Taxes are chargeable at the federal, state and local
• Corporations incorporated in the United States (US) are generally subject to tax on their worldwide income. Certain dividends received from a foreign corporation are eligible for a 100% dividends received deduction when requirements are To avoid any double taxation on foreign branch income, foreign tax deductions or credits are available. To prevent a double utilisation of foreign branch loss by both US and foreign jurisdiction, US tax owners are required to file domestic use elections in order to utilise such loss in the US.
• Foreign corporations are generally subject to US income tax on their income effectively connected to a US trade or business.
• A US corporation is entitled to a special deduction for dividends received from other domestic corporations.
• For corporations, capital gains are taxed at the same rates applicable to ordinary income.
• The tax on a foreign corporation’s US branch’s profits and earnings is the same as regular corporate tax, but an additional 30% branch profits tax (BPT) is imposed if the after-tax earnings of the branch are not reinvested in the business by the close of the tax year or if the earnings are repatriated in a later tax year. Certain tax treaties may reduce the BPT.
• The US does not impose any However, most states impose single stage sales and use tax. Following a US Supreme Court decision in 2018, many states have implemented new rules requiring out-of-state sellers to collect and remit sales tax to the state under certain circumstances, even without having physical presence in that state.
• Related party transactions negotiated at arm’s length and meeting rigid substantiation standards are treated the same way as non-related party transactions.
• In general, taxes are required to be withheld from US source portfolio income, at 30%, such as dividends, interest, rents, royalties, and certain other types of income paid to non-US US tax treaties with a foreign country may provide reduced withholding tax rates, as low as 0%, when certain requirements are met or the treaties may give the ability to allocate the right to tax income to one of the treaty countries so that there is no withholding tax at all. Also, under certain circumstances, an exception to withholding tax on interest payments (the “portfolio interest exemption”) may apply.
• The Foreign Account Tax Compliance Act of 2010 (FATCA) imposes broad reporting and withholding obligations (directly and indirectly) on most non-US entities receiving US-source income. This is in addition to regular tax withholding. FATCA also imposes reporting obligations for foreign entities such as foreign financial institutions that have US citizen and US resident account holders, and certain non-financial entities in which US citizens or US residents own foreign assets.
• US citizens and residents are subject to taxation and reporting requirements on their worldwide income even if they are not residing in the US. US citizens and residents living abroad may be entitled to a Foreign Earned Income Credit or Foreign Tax Credit, as allowed by treaty, to mitigate double taxation on income.
• Non-resident individuals are generally subject to tax on their income generated from US sources.
• The taxation of digital assets is an evolving area on a federal and state Digital assets include, but are not limited to, convertible virtual currency and cryptocurrency, stablecoins, and non-fungible tokens (NFTs). Digital assets are treated as property and general tax principles apply.
• Special lower tax rates apply to capital gains and dividend income of individuals, depending on how long the asset has been held, the type of asset and the taxpayer’s income tax bracket.
• Other taxes for individuals which may be levied include alternative minimum tax (AMT), self-employment tax, social security and Medicare tax and qualified retirement plan Taxes paid to the states and municipalities are generally deductible on the federal income tax return in the year paid, subject to limitations. However, for taxable years beginning after 31 December 2017 and before 1 January 2026, the state and local deduction is limited to USD 10,000 for individual taxpayers or persons who are married filing a joint return (USD 5,000 for married individuals filing separate returns). Some states have implemented Pass- Through-Entity-Tax rules for partnerships and S corporations. These rules allow a pass-through-entity, which otherwise would not be subject to tax themselves, to elect to pay state tax on behalf of its owners. If elected, this allows owners of these pass- through entities to deduct such state and local taxes paid by the entity, even if they are in excess of the cap described above.

Key Tax Points

• Corporate net income obtained by legal entities resident in Uruguay and by non-residents operating through a permanent establishment is taxed by IRAE at a rate of 25%.
• Uruguay operates a territorial system of taxation, subject to certain exceptions regarding worldwide taxation.
• Personal income tax: Uruguay classifies income into two Category I is generally non-exempt passive income, and Category II is employment/service income.

• The standard VAT rate is 22% but there is a reduced rate of 10% for certain items while some are VAT-exempt.

Key Tax Points

• Enterprises (i.e. legal entities) are generally subject to corporate income tax at the rate of 15%. Commercial banks, producers of cement and polyethylene granules, mobile services providers, and markets/shopping malls are subject to corporate income tax at the rate of 20%.
• An optional simplified tax regime is available for all legal entities with annual turnover of less than UZS 1 billion and individual entrepreneurs with turnover ranging from UZS 100 million to UZS 1 Under this regime, turnover tax replaces corporate income tax and VAT.
• From 1 January 2023, the standard VAT rate is 12% (previously: 15%).
• An individual taxpayer is obliged to register for VAT if his taxable turnover in a year exceeds UZS 1 Except in the case of individuals, persons are generally treated as VAT payers regardless of their turnover. Taxpayers whose income does not exceed the turnover tax regime threshold (see above) may opt to pay turnover tax, instead of VAT.
• Ordinary losses can be carried forward for an indefinite period and can be used without any restrictions to reduce the current year’s taxable income. Losses cannot be carried back.
• Dividends distributed to non-resident companies are subject to a 10% final withholding tax on the gross amount, subject to the application of a double tax treaty. Starting from 1 April 2022 until 31 December 2024, dividends paid by resident legal entities to non-resident legal entities are subject to a 5% reduced withholding tax This reduced rate was extended until 31 December 2028.
• Interest paid to non-resident companies is subject to a 10% final withholding tax on the gross amount, subject to the application of a double tax Starting from 1 April 2022 until 31 December 2024, interest income from bonds is exempt from taxation. This exemption was extended until 31 December 2028.
• Royalties, technical fees and management fees paid to non-resident companies are subject to a 20% final withholding tax, subject to the application of a double tax treaty.
• Transfer pricing, controlled foreign companies (CFC) and group taxation regulations were introduced effective 1 January 2022.
• Thin capitalisation regulations were introduced effective 1 January 2020.

Key Tax Points

• Venezuelan resident or domiciled companies are subject to profit tax only on their worldwide income whereas non-residents are subject to tax on their Venezuelan source income even when they do not have a permanent establishment or a fixed base in Venezuela.
• There is a progressive system of corporation tax rates which applies to income and capital gains.
• VAT is payable on imports and the supply of goods and The standard rate is 16%.
• Regarding VAT, a new “additional tax rate” or surcharge tax ranging from 5% to 25% is applicable to the payment of goods and services in foreign currencies or in cryptocurrencies different from those backed by the The surcharge tax entered into force on 28 February 2020.
• Withholding taxes apply to interest and royalty payments to residents and non-residents. Dividends are also subject to withholding tax when they represent profits that have not been subject to corporation A similar principle applies to branch profits repatriated from Venezuela to an overseas territory.
• Credit is available for overseas tax paid on foreign income against Venezuelan tax payable on the same income.
• A wealth tax was introduced in August 2019 and will apply to individuals and legal entities, designated as “special taxpayers” by the tax authorities, which own or possess wealth with a value exceeding 150 million tax units (TUs).
• Resident individuals are subject to income tax on their worldwide Non-residents are taxable on their Venezuelan source income.

• Tax on large financial transactions is levied at a rate of 2% and 3%. This tax has come into effect on 25 March 2022 (“Law of Tax on Large Financial Transactions”).
• In August 2018, the Venezuelan government announced a monetary reconversion which created a new currency, the Sovereign Bolivar, which gradually replaced from 20 August 2018 the previous currency Strong Bolivar at a conversion rate of Sovereign Bolivar 1 to Strong Bolivar 100,000. Entities need to adapt their systems and processes to the new currency.
• In August, 2021, the Venezuelan government announced a new monetary reconversion which created a new currency, the Digital Bolivar, which gradually replaces from 1 October 2021 the previous currency the Sovereign Bolivar at a conversion rate of Digital Bolivar 1 to Sovereign Bolivar 1,000,000.
• Entities need to adapt their systems and processes to the new currency.

Key Tax Points

• Corporate Income Tax (CIT) is a direct tax levied on the profit earned by an enterprise carrying on a trade or business in Vietnam. All income (including income from overseas) of enterprises registered in accordance with the Vietnamese Law of Enterprises is subject to Corporate Income Tax.
• Vietnam’s standard corporate tax rate is 20%.
• Personal Income Tax (PIT) for resident individuals is levied on their income earned within and outside Vietnam’s territory, while non-residents are taxed only on their income earned in Vietnam.
• There are three VAT rates in In general, goods or services are subject to a rate of 10%, while some goods or services are subject to a rate of 5% and a 0% rate is applied for goods and services exported abroad.
• Excise Tax (ET) is an indirect tax levied on certain luxury goods and services.

Key Tax Points

• The standard corporate income tax rate is 20%.
• The standard GST rate is 5%.
• Losses can be carried forward for 5 years subject to certain Carry-back of losses is not allowed.
• Dividends paid by a resident company to a non-resident company are not subject to withholding tax if such dividends are paid out of profits which have already been subject to tax.
• Interest paid to a non-resident company without a PE in Yemen is subject to a 10% withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

• Royalties paid to a non-resident company without a PE in Yemen are subject to a 10% withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

• Service fees and management fees paid to non-resident companies are subject to a 10% withholding tax rate on the gross amount, unless a lower tax treaty rate applies.

Key Tax Points

• Companies whether resident or non-resident and are in receipt of income, which has a source or deemed source in Zambia, are liable for tax.
• Standard Corporate Income Tax payable by Zambian companies on their taxable income is 30%. The tax is payable by both public and private companies as well as small businesses. Other concessional income tax rates are as follows:

• There is no capital gains tax in Instead there is what is known as Property Transfer Tax (PTT) which is levied on the sale or deemed sale of all immovable property, shares and intellectual property at 8% of the realisable value. PTT is also levied on the transfer of a mining right for a mining licence, a mineral processing licence at 10% of the realised value while transfer of a mining right for an exploration licence is at 8% of the realised value.
• VAT is chargeable on all taxable goods and services supplied by a registered supplier at a standard rate of 16%. Where cross- border services are engaged in, reverse VAT needs to be paid on the foreign supplier of service using an approved tax This is applicable where the recipient of the services is registered for VAT in Zambia.
• Zambian resident individuals and companies are subject to tax in Zambia on foreign interest and dividends.
• Tax credits are granted in respect of foreign taxes paid on foreign sources of income in accordance with the Income Tax Act and the numerous Double Tax Treaties.

• Mineral royalty is a deductible expenditure in computing the tax taxable income for any person that has paid mineral royalty in accordance with the Mines and Minerals Development Act, 2015.
• Group taxation is not applicable in All group companies are taxed as separate entities.
• The Zambia Revenue Authority Commissioner-General is empowered to make adjustments to non-arm’s length cross-border transactions and thin capitalisation between related parties.
• Income from royalties, commission, dividends, management and consultancy and other professional services are subject to withholding taxes when received by Non-residents are subject to withholding tax on payments for construction and haulage operations, royalties, management & consultancy, commission, public entertainment, dividends and interest.
• Zambian resident individuals are subject to tax on their income from a source or deemed source within Foreign interest and dividends received by individuals ordinarily resident in Zambia including companies are taxable.

Key Tax Points

• Resident companies and private business corporations are taxed on non-exempt income from a source within or deemed to be within Income from a foreign source attracts tax only if it falls within the specific provisions relating to deemed source.
• Normal tax is payable by Zimbabwean companies on their taxable income at the rate of 25%. A 3% AIDS levy is imposed on the tax chargeable giving an effective tax rate of 25.75%.
• A new Domestic Minimum Top Up Tax (DMTT) was introduced with effect from 1 January 2024 on “foreign entities” as defined to guard against ceding taxing rights to foreign jurisdictions as a result of tax incentives that are provided to investors. A minimum tax of 15% is levied in Zimbabwe on such entities where the effective rate of tax paid by such entities in Zimbabwe is less than 15% of the taxable income earned in Where there are Double Taxation Agreements (DTAs) the greater of 15% and the DTA rate is charged. However, the legislation on this is still under development.
• Capital Gains Tax (CGT) is levied on taxable gains from a source within Zimbabwe from the sale or deemed sale of immovable property and any marketable security (specified asset). Specified asset includes trademarks, brands and any right to property (tangible or not tangible) for CGT.
• With effect from 1 January 2024, a special Capital Gains Tax (CGT) of 20% on the value of the transaction is charged on the disposal of any mining title, share, stake, right, or interest in any mining This tax is payable by the transferee, failure of which it defaults to the transferor of the mining title. It applies to both residents and non-residents.
• Payments under the Global Compensation Deed for expropriating agricultural land are not subject to CGT, effective from 1 January 2024.

• With effect from 1 January 2024, a wealth tax was introduced and is charged at 1% on the rateable value of the dwelling qualifying for the Dwellings with a value of USD 250,000 and below are exempt from this tax. Principal private residences are exempted. The tax liability has a maximum cap of USD 50,000 per annum. This tax will initially be collected by the local authorities in which the dwelling is situated until ZIMRA has set up the necessary collection framework.
• A 2% levy is charged on exportation or local sale of lithium, uncut and cut dimensional stone, black granite and quarry stones with effect from 1 January 2025. The levy is payable in the currency of trade.
• The Commissioner General is now allowed to have access to moneys, funds and assets that are deposited with professional custodians (which include financial institutions, designated business or professional service as defined in the Money Laundering and Proceeds of Crime Act (Chapter 9:24)) for safe keeping and where a person has a tax The powers extend to seizure of such assets.
• Powers of the Commissioner were amended to empower the Commissioner to:
  1. Require any person to prepare, grant access rights and additionally, or alternatively, to produce for inspection any electronic and digital equipment or platforms with capacity to store, process and manage data, printout or other reproduction of any information stored in a computer or other information retrieval system or platform;
  2. Seize any USB or any other electronic storage devices on the person or premises covered by the warranty;
  3. Seize stock in trade of the tax debtor on any premises covered by a warranty; and
  4. Seize cash of the tax debtor on any premises covered by the
• VAT is imposed on all goods and services supplied by a registered operator at a standard rate of 15% with a few basics being exempt. Effective 1 January 2024, the VAT registration threshold was reduced from USD 40,000 to USD 25,000 (or local currency equivalent).
• The VAT Regulations have been amended to remove the Second Schedule which listed the zero-rated items. Some goods and services were moved to the exemption list and a few became standard rated with effect from 1 January However, effective from 12 June 2024, the VAT regulations were amended to reintroduce the Second Schedule with zero-rating of gold supplied to Fidelity Gold Refinery (Private) Limited only in order to boost economic growth.

• Route to market measures were introduced on 1 January 2024 in a bid to ensure the value chain integrity and transparency and to protect the tax base.

• Zimbabwean resident individuals and corporates are subject to tax in Zimbabwe on foreign interest and dividends. Foreign dividends are subject to tax at a flat rate of 20%. Expatriates working in Special Economic Zones are subject to tax at a 15% flat tax rate on their remuneration.
• Tax credits are granted in respect of foreign taxes paid on foreign sources income in accordance with the Income Tax Act and numerous Double Tax Agreements.

• Group taxation is not However, corporate rules exist which provide relief in respect of transactions between group companies and between founding shareholders and their company.

• The Revenue Authority Commissioner is empowered to make adjustments to non-arm’s length cross-border and local transactions and thin capitalisations between connected parties. Specific transfer pricing rules took effect from 1 January 2016. Locally contracted debt with unrelated parties is excluded from the thin capitalisation rule which stipulates a ratio of 3:1.
• Income from royalties, dividends, interest, and similar income are subject to withholding taxes at Non-residents are subject to withholding tax on dividends, royalties, fees (including non-executive directors’ fees) and remittances. There is no withholding tax on interest paid to non-residents.
• Zimbabwean resident individuals are, save for certain exclusions, subject to tax on their income from a source within Zimbabwe. Non-resident individuals, subject to certain exclusions, are subject to tax on their Zimbabwe-sourced income only.