Direct taxes - Corporate Income Tax

    Generic part



    Contact information

    Administration

    Service

    Website

    E-mail

    Telephone

    Who sets

    The tax rate is set by





    The tax base is set by





    The reliefs are set by





    Beneficiary






    Geographical Scope

    Taxpayers

    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

    Buildings








    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:

    Losses

    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 -

    Footnotes