Direct taxes - Corporate Income Tax

    Generic part

    Contact information






    Who sets

    The tax rate is set by

    The tax base is set by

    The reliefs are set by


    Geographical Scope


    Which entities are liable for CIT?

    Which entities are exempt from CIT?

    Domestic-source income of non-resident entities is

    Tax object and basis of assessment

    As general rule, taxable income under corporate income tax includes also

    Income considered

    Deductions, allowances, credits, exemptions

    Valuation of inventory

    Depreciation rules


    Other fixed immovable assets (e.g. machinery)

    Movable (tangible) assets (e.g. cars, furniture, work equipment)

    Intangible assets (e.g. patents)

    Land (if any)

    Are there limits to interest deductions (other than thin capital rules)?

    Is there an Allowance for Corporate Equity?

    Exemptions from taxable income

    Expenses that are generally not deductible:


    Loss carry-forward exists?

    Loss carry-backward exists?

    Tax credits available?

    Rate(s) Structure

    Special tax rate for SMEs

    Measures against profit shifting

    Do Thin Capitalization (TC) rules exist?

    TC depends on shareholding?

    Automatic remedy

    Transfer pricing rules exists?

    Special features

    Is group taxation available?

    Is there a specific anti-avoidance provision in the legislation?

    International aspects

    Treaty countries
    Non-treaty countries
    Repatriated profits are taxed according to the following system

    Interest received is taxed
    Tax rate on interest received
    Outgoing dividends withholding tax
    Outgoing royalty payments withholding tax
    Outgoing interest payments withholding tax
    Foreign losses (of either subsidiaries or permanent establishments) can be set-off
    If yes :
    Minimum direct or indirect shareholding to qualify loss-offset (if applicable)
    Loss carry-forward exists?
    If yes :
    Time limit
    Size limit
    Loss carry-backward exists?
    If yes :
    Time limit
    Size limit
    Controlled foreign company (CFC-) rules exist?
    If yes :
    Time limit:
    Size limit
    Threshold for capital or voting power held directly or indirectly by resident in non-resident company:
    CFC-rules apply if foreign tax rate is lower than:
    CFC-rules apply for passive income only?

    Tax due date

    When has the tax return to be filed

    Advance tax payments due?

    Tax collector

    General comments

    Economic function

    Environmental taxes

    Tax revenue

    Year Annual tax revenue (in millions) % of GDP % of total tax revenue -