Global Tax Guide

Review of International Tax Regimes: Key Themes, Ideas, and Facts

This briefing document summarises key themes, important ideas, and facts extracted from the provided international tax sources. It offers a comparative overview of corporate and individual taxation, withholding taxes, capital gains, and indirect taxes across various jurisdictions, highlighting commonalities, significant differences, and emerging trends.

1. Corporate Taxation: Rates, Residency, and Scope

The primary corporate tax levied across most jurisdictions is a Corporation Tax or Industrial Tax (Imposto Industrial). Rates and the scope of taxation vary significantly:

• Residency and Worldwide vs. Territorial Income:
• Most resident corporations are subject to tax on their worldwide income. Examples include Australia (incorporated or management and control in Australia), Belgium (central management in Belgium), Cyprus (control and management in Cyprus), Denmark (incorporated or central management in Denmark), India (domestic companies), Israel, Italy, Japan, Kenya, Mozambique, New Zealand, Peru, Singapore, Switzerland, UK, and Uganda.
• Non-resident corporations are generally taxed only on income sourced within the jurisdiction or profits attributable to a Permanent Establishment (PE).
• Some countries, like Angola, apply Corporate Income Withholding Tax on services provided to entities established in Angola for tax purposes, regardless of a PE.
• Hong Kong SAR operates on a territorial basis, taxing profits “arising in or derived from Hong Kong”. However, its newly enacted Foreign-Sourced Income Exemption (FSIE) regime (effective January 1, 2023) taxes specified foreign-sourced income accrued and received in Hong Kong by multinational entities, unless certain exception conditions are met.
• Ecuador’s regime levies tax on Dominican-source income and foreign-source investment/financial gains for residents.
• Finland has a territorial approach since 2006, where a Danish company is only taxed on profit from Danish activity, not foreign PEs or immovable property, unless international group taxation is selected.
• French Polynesia adheres strictly to the “Territoriality principle: tax is only due on business generated by enterprises registered and operating in French Polynesia.”
• Ghana taxes residents on worldwide income and non-residents with a PE on worldwide income.
• Gibraltar taxes profits “accrued in or derived from” the territory, defined by the location of income-generating activities.
• Iraq levies tax on worldwide income for residents, and on income generated in Iraq for branches of foreign companies.
• Jamaica taxes residents on worldwide income, and non-residents only on income arising in or derived from Jamaica.
• Kuwait only taxes non-resident companies and foreign partners on net profit from Kuwaiti operations.
• Standard Corporate Tax Rates (General Regime):
• Low/Zero Tax: Barbados (0%), The Bahamas (0% with proposed QDMTT), British Virgin Islands (0%), Cayman Islands (0%), Guernsey (0%), Jersey (0%), Kuwait (None for residents, 20% for non-resident taxable profit), Isle of Man (0% with exceptions).
• Moderate Rates: Bulgaria (10%), Cambodia (20% for most), Cyprus (12.5%), Denmark (22%), Estonia (20% on distributed profits), Finland (20%), France (25% by 2020), Germany (15% for Corporation Tax, plus Trade Tax), Ghana (25%), Greece (22% from 2021, 29% for credit institutions), Honduras (25% plus 5% solidarity tax), Hungary (9%), India (30%, with concessional rates of 15% and 22% for new/qualifying companies), Indonesia (25%, 20% for public companies meeting listing requirements, 1% for small enterprises), Ireland (12.5% for trading income, 25% for passive income), Israel (23%), Italy (24% IRES, plus IRAP), Japan (23.2% national, lower for small corporations), Jordan (20% to 30%, plus national contribution), Kazakhstan (20%), Kenya (30%), Korea (South) (10-24% progressive, plus 10% local income surtax), Lebanon (15%), Luxembourg (17% to 22.8% progressive), Malaysia (24%), Mexico (30%), Mozambique (32%), Myanmar (25%), Netherlands (15-25%), New Zealand (28%), Nigeria (30%), Norway (22%), Pakistan (29%), Peru (26%-28%), Philippines (20-30%), Poland (19%), Portugal (21%), Puerto Rico (20-37.5%), Romania (16%), Russian Federation (20%), Saudi Arabia (20% for non-resident taxable profit), Serbia (15%), Singapore (17%), Slovakia (21%), Slovenia (19%), South Africa (27% from 2023), Spain (25%), Sri Lanka (24%), Sweden (20.6%), Switzerland (11.9% to 21% average), Taiwan (17%), Tanzania (30%), Thailand (20%, lower for small companies), Tunisia (25-35%), Turkey (25%), Uganda (30%), UK (25%), Venezuela (15-50%), Vietnam (20%).
• Higher Rates: Albania (50% windfall tax on energy producers), Angola (25%, 10% for agriculture, 35% for oil/banks/insurance/telecoms), Argentina (25-35% progressive, 41.5% for gaming), Azerbaijan (20%), Bolivia (25%), Brazil (15% plus 10% surtax, 9% Social Contribution, effectively 34%), Chad (30%, 25% for industrial/energy), Chile (27%), Colombia (35% general, 3% to 15% for financial/digital services), Congo, DR (30%), Congo, Rep. of (30%), Costa Rica (30%, 25% for companies under USD150k turnover), Dominican Republic (27%), Ecuador (25%, 30% for over USD150k turnover), El Salvador (25-30%), Equatorial Guinea (35%), Gabon (30-35%), Guatemala (25%), Guyana (40%, 45% for telephone, 25% for non-commercial), Nigeria (30%, 50% for oil and gas).
• Specialized Rates/Incentives/Exemptions:
• Agriculture/Mining/Specific Industries: Many countries offer reduced rates or exemptions for specific sectors (e.g., Angola, Brazil, Cambodia, Ghana, Honduras, India, Indonesia, Kenya, Myanmar, Namibia, Nigeria, Tanzania, Thailand, Uganda, Vietnam).
• Small/Medium Enterprises (SMEs): Often benefit from lower rates or simplified regimes (e.g., Australia, Brazil, France, Honduras, Hungary, India, Indonesia, Kenya, Korea (South), Peru, Portugal, Singapore, Slovakia, Thailand, UK).
• Investment Incentives: Numerous countries provide tax holidays, credits, or deductions for qualifying investments, R&D, and job creation (e.g., Albania, Algeria, Angola, Belgium, Cambodia, Canada, Czech Republic, Denmark, Dominican Republic, Ecuador, Egypt, Finland, France, Germany, Ghana, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kenya, Korea (South), Malaysia, Malta, Myanmar, Netherlands, Nigeria, Pakistan, Philippines, Portugal, Puerto Rico, Romania, Saudi Arabia, Serbia, Singapore, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Holding Companies/Participations: Many jurisdictions offer participation exemptions for dividends and capital gains from qualifying shareholdings (e.g., Belgium, Cyprus, Finland, France, Germany, Greece, Indonesia, Ireland, Israel, Italy, Japan, Luxembourg, Malaysia, Netherlands, Portugal, Singapore, South Africa, Spain, Switzerland, UK).
• Exempt Entities: Specific entities or activities might be fully exempt (e.g., Bermuda (Exempt Companies for financing, investing, holding shares), Brunei Darussalam (certain income from non-resident entities not received in Brunei), Cayman Islands, Guernsey, Jersey, Isle of Man, The Bahamas (previously IBCs, now with new QDMTT considerations)).
• Notional Interest Deduction (NID): Belgium and Cyprus offered NID, with Belgium’s regime now abolished for tax periods ending on or after Dec 31, 2023.

2. Individual Taxation: Income Tax and Residency

Individual income tax regimes typically differentiate between residents and non-residents, with residents usually taxed on worldwide income and non-residents on domestic-source income.

• Residency Criteria: Often based on physical presence (e.g., 183 days rule in Cambodia, Ireland, Russian Federation, Vietnam), “domicile” or “principal place of abode” (Cambodia), “center of vital interests” (Azerbaijan), or “ordinarily resident” (South Africa).
• Income Scope:Residents: Generally taxed on worldwide income (e.g., Australia, Belgium, Brazil, Bulgaria, Cambodia, Colombia, Croatia, Czech Republic, Denmark, Ecuador, Egypt, Finland, France (Solidarity Tax only in French Polynesia), Ghana, Greece, Guatemala, Honduras, Hungary, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Russian Federation, Saudi Arabia (None), Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Non-residents: Generally taxed only on income sourced within the jurisdiction (e.g., Australia, Belgium, Brazil, Bulgaria, Cambodia, Colombia, Croatia, Czech Republic, Denmark, Ecuador, Egypt, El Salvador, Finland, France (French Polynesia only on local source), Ghana, Greece, Guatemala, Honduras, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Russian Federation, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Tax Rates (Progressive vs. Flat):Many countries employ progressive tax rates for individuals (e.g., Albania, Australia, Belgium, Brazil, Bulgaria, Cambodia, Colombia, Costa Rica, Croatia, Czech Republic, Denmark, Ecuador, Egypt, El Salvador, Estonia, Finland, France, Gabon, Germany, Ghana, Greece, Guatemala, Honduras, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Russian Federation, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Some have flat rates or a basic tax-free amount (e.g., Barbados (Basic personal amount tax-free: $25,000, then progressive), French Polynesia (no individual Income Tax but a Solidarity Tax)).
• Allowances and Deductions: Commonly include social insurance contributions, pension funds, and various personal allowances. Specific regimes exist for expats in some countries (e.g., Belgium).

3. Capital Gains Tax (CGT): Diverse Approaches

The taxation of capital gains varies significantly, ranging from full exemption to integration with ordinary income or specific CGT regimes.

• No Capital Gains Tax: Barbados, British Virgin Islands, Cayman Islands, Guernsey, Isle of Man, Kuwait, Romania.
• Integrated with Corporate/Individual Income Tax:Many countries treat capital gains as ordinary income, subject to standard corporate or individual income tax rates (e.g., Australia, Azerbaijan, Belgium, Bulgaria, Cambodia, Colombia, Costa Rica, Croatia, Cyprus (for companies), Denmark (for portfolio shares), Ecuador, Egypt, Finland (for private equity investors), French Polynesia, Gabon, Germany, Ghana, Guatemala, Honduras, Hungary, India, Indonesia, Ireland (for companies on development land/shares), Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand (certain gains from land and foreign investment), Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Puerto Rico, Russian Federation, Saudi Arabia (None for residents), Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Specific CGT Regimes/Rates:Argentina: 0/15/25 to 35% for corporations, 15% for foreign residents on unlisted shares.
• Cyprus: “Gains of any person accruing from the disposal of immovable property or shares in a company that owns immovable property located in Cyprus.”
• El Salvador: 10% on movable/immovable property, 25-30% if sold within 12 months.
• Greece: Real estate and securities at 15%.
• India: Progressive rates, with special concessional rates for long-term capital gains on listed securities (e.g., 10% over INR100,000, 15% for short-term).
• Israel: Reduced rate of 6% on IP-based income and capital gains from IP sales for qualifying companies.
• Korea (South): 6-70% for land/buildings, 10-30% for shares.
• Morocco: 20% on real estate assets, 0-20% on movable capital.
• Pakistan: 15% to 29% for immovable property, 15% for listed securities.
• Philippines: 6% on net gains from sale of real property; 5-10% on net gains from sale of shares not traded.
• Spain: 19-28% for individuals, 25% for corporations.
• Turkey: Progressive rates for securities held less than 2 years, immovable property less than 5 years.
• Uganda: Taxed upon realization.

4. Inheritance Tax (IHT) / Estate Tax: Presence and Rates

IHT or Estate Tax is not universally applied, with many countries opting out or having varying structures.

• No Inheritance Tax: Azerbaijan, Barbados, British Virgin Islands, Cayman Islands, Estonia, Guernsey, India, Indonesia, Isle of Man, Kuwait, New Zealand, Peru, Romania, Saudi Arabia.
• Levied on Gratuitous Transfers/Estates:Angola: Progressive rates (10-15% for spouses/ascendants/descendants, 20-30% for others). Exemptions for transfers below 500,000 Kwanzas to certain relatives.
• Brazil: 4% in São Paulo (variable by state).
• Finland: Progressive rates based on market value, allowances for household belongings, spouse, and minors.
• Greece: 0-40% depending on value and kinship. Movable and immovable estate situated in Greece.
• Guatemala: Based on relationship to deceased.
• Italy: 4-8% based on kinship, plus 3% on inherited real estate (or €400 for first house). Tax-free franchises for spouses/lineal relatives (€1m), siblings (€100k).
• Korea (South): Levied on value of assets acquired on death, after deductions.
• Philippines: 5-20% progressive on net estate.
• Portugal: Abolished, but 10% Stamp Tax on inheritance/gifts (exempt for spouses/ascendants/descendants).
• South Africa: 20% to 25% on dutiable value.
• Spain: 7.65% to 34% (variable by autonomous community).
• Sri Lanka: 24% on property transferred on death.
• UK: 20% on chargeable lifetime transfers, 40% on estates/gifts made 7 years prior to death (reduced to 36% with charity donation). Nil rate band £325,000. Non-UK domiciled individuals taxed only on UK assets.

5. Withholding Taxes (WHT): Dividends, Interest, Royalties, and Services

WHTs are imposed on payments to non-residents (and sometimes residents) for various types of income. Double Taxation Treaties (DTTs) frequently reduce these rates.

• Dividends (General Non-resident Rate):
• Often between 0% and 30%, with lower rates under DTTs.
• Common Exemptions: Payments to resident companies, or to qualifying EU/EEA parent companies under directives (e.g., Belgium, Czech Republic, Cyprus, Denmark, Finland, France, Germany, Ireland, Italy, Netherlands, Poland, Slovakia, Slovenia, Spain, UK).
• High: Argentina (0/7/35%), Belgium (30%), Brazil (Nil, except to tax havens), Colombia (0% for distributions from taxed profits, 35% for others), Dominican Republic (27%), Ecuador (0% to 10% for residents, 0% to tax havens, differential for others), France (25/75%), Greece (5%), India (20%), Israel (25-30%), Italy (26%), Japan (20%), Lebanon (10%), Luxembourg (15%), Malaysia (0%), Mexico (10%), Nigeria (10%), Pakistan (15%), Philippines (15-20%), Portugal (25%), Puerto Rico (10%), Russian Federation (15%), Serbia (15%), Slovakia (7%), Slovenia (15%), South Africa (20%), Spain (19%), Sri Lanka (14%), Sweden (30%), Switzerland (35%), Taiwan (20%), Tanzania (15%), Thailand (10%), Tunisia (10%), Turkey (15%), Uganda (15%), UK (Nil), Venezuela (34%), Vietnam (5% for residents, 0% for non-residents if not reinvested).
• Low/Zero: Angola (0% if subject to Investment Income Tax), Barbados (Nil), British Virgin Islands (0%), Brunei Darussalam (0%), Bulgaria (5%), Cambodia (14%), Cayman Islands (0%), Cyprus (Nil), Denmark (22% refundable to 27%), Estonia (20% on distribution, 7% for individuals), Finland (20% on distribution), Georgia (5%), Guernsey (Nil), Hong Kong SAR (0%), Honduras (10%), Hungary (0%), Indonesia (15% for corporations, 10% for individuals), Isle of Man (Nil), Jersey (Nil), Jordan (10%), Kazakhstan (15%), Kenya (5% for residents, 15% for non-residents), Korea (South) (22% statutory, 10% for local income tax), Kuwait (Nil), Malta (0%), Myanmar (0%), Netherlands (15%), New Zealand (0%-30%), Norway (25%), Panama (10%), Qatar (0%), Rwanda (15%), Saudi Arabia (Nil).
• Interest (General Non-resident Rate):
• Often between 0% and 30%, with lower rates under DTTs.
• Common Exemptions: Payments to government entities, central banks, or financial institutions (e.g., Czech Republic, Denmark, Germany, Italy, Japan, Netherlands, Norway, Poland, Portugal, Russian Federation, Slovakia, Slovenia, Spain, UK).
• High: Argentina (15.05/35%), Belgium (30%), Brazil (15-25%), Colombia (15%), Denmark (22%), Dominican Republic (10%), Ecuador (15%), El Salvador (20%), France (20/30%), Greece (15%), Honduras (10%), India (20%), Israel (23% for residents, 0% to 23% for non-residents), Italy (26%), Japan (20%), Jordan (10%), Kenya (15%), Korea (South) (22%), Lebanon (10%), Luxembourg (20%), Malaysia (15%), Mexico (4.9-35%), Nigeria (10%), Pakistan (10%), Philippines (20%), Portugal (25%), Puerto Rico (20%), Russian Federation (20%), Serbia (20%), Slovakia (20%), Slovenia (20%), South Africa (20%), Spain (19%), Sri Lanka (10%), Sweden (30%), Switzerland (35%), Taiwan (15%), Tanzania (10%), Thailand (15%), Tunisia (20%), Turkey (15%), Uganda (15%), UK (20%), Venezuela (34%), Vietnam (5%).
• Low/Zero: Angola (0%), Barbados (Nil), British Virgin Islands (0%), Brunei Darussalam (2.5%), Bulgaria (10%), Cambodia (15%), Cayman Islands (0%), Cyprus (Nil), Estonia (0% for companies, 20% for individuals), Finland (0%), Georgia (0% for enterprises), Guernsey (Nil), Hong Kong SAR (0%), Hungary (0%), Indonesia (15% by non-banks, 20% by banks for residents, 0% to 20% for non-residents), Isle of Man (Nil), Jersey (Nil), Kazakhstan (15%), Kuwait (Nil), Malta (0%), Myanmar (0%), Netherlands (0%), New Zealand (15%), Norway (25%), Panama (12.5%), Qatar (0%), Rwanda (15%), Saudi Arabia (Nil).
• Royalties (General Non-resident Rate):
• Often between 0% and 30%, with lower rates under DTTs.
• High: Albania (30%, effective 21% for software, 12% for leasing), Argentina (21/28/31.5%), Belgium (30%), Brazil (15-25% plus 10% CIDE), Colombia (20%), Dominican Republic (27%), Ecuador (25%), El Salvador (20%), France (20/30%), Greece (20%), Honduras (10%), India (20%), Israel (23%), Italy (30%, effective 22.5% on 75%), Japan (20%), Kenya (20%), Korea (South) (22%), Lebanon (10%), Luxembourg (20%), Malaysia (10%), Mexico (25-30%), Mozambique (20%), Nigeria (10%), Pakistan (15%), Philippines (25%), Portugal (25%), Puerto Rico (20%), Russian Federation (20%), Serbia (20%), Slovakia (20%), Slovenia (20%), South Africa (20%), Spain (24%), Sri Lanka (10%), Sweden (20%), Switzerland (Nil, but often taxed as business profits), Taiwan (20%), Tanzania (15%), Thailand (15%), Tunisia (15%), Turkey (20%), Uganda (15%), UK (20%), Venezuela (34%), Vietnam (10%).
• Low/Zero: Angola (0%), Barbados (Nil), British Virgin Islands (0%), Brunei Darussalam (10%), Bulgaria (10%), Cambodia (14%), Cayman Islands (0%), Cyprus (Nil), Denmark (22%), Estonia (Nil), Finland (0%), Georgia (0%), Guernsey (Nil), Hong Kong SAR (4.95-16.5%), Hungary (0%), Indonesia (20%), Isle of Man (Nil), Jersey (Nil), Jordan (10%), Kazakhstan (15%), Kuwait (Nil), Malta (0%), Myanmar (0%), Netherlands (0%), New Zealand (15%), Norway (25%), Panama (12.5%), Qatar (0%), Rwanda (15%), Saudi Arabia (Nil).
• Services/Technical Fees: Many countries impose WHT on services, technical assistance, or management fees, especially for non-residents (e.g., Algeria (30%), Argentina (21/28/31.5% for patents/know-how), Brazil (25% for services), Colombia (20%), Congo, DR (10-20%), Congo, Rep. of (20%), Dominican Republic (27%), Ecuador (25%), Egypt (20%), El Salvador (20%), France (15%), Ghana (15% for most, 5% for technical fees), Guatemala (15%), Guyana (10% to 20%), Honduras (10%), India (20%), Indonesia (20%), Israel (23%), Italy (20% for professionals/self-employed), Japan (20%), Jordan (10%), Kazakhstan (20%), Kenya (20%), Korea (South) (20%), Lebanon (10%), Luxembourg (20%), Malaysia (10%), Mexico (25-30%), Mozambique (20%), Myanmar (0%), Netherlands (Nil), New Zealand (Nil), Nigeria (5%), Norway (25%), Pakistan (15%), Peru (30%), Philippines (25%), Poland (20%), Portugal (25%), Puerto Rico (29%), Russian Federation (20%), Saudi Arabia (5%), Serbia (20%), Singapore (17%), Slovakia (20%), Slovenia (20%), South Africa (20%), Spain (24%), Sri Lanka (10%), Sweden (20%), Switzerland (Nil), Taiwan (20%), Tanzania (15%), Thailand (15%), Tunisia (15%), Turkey (20%), Uganda (15%), UK (20%), Venezuela (34%), Vietnam (5%).

6. Indirect Taxes: VAT/GST and Other Levies

Value Added Tax (VAT) or Goods and Services Tax (GST) is a widespread consumption tax, with varying rates and exemptions.

• VAT/GST (Standard Rate):High: Hungary (27%), Croatia (25%), Denmark (25%), Finland (24%), Greece (24%), Ireland (23%), Norway (25%), Poland (23%), Portugal (23%), Sweden (25%), UK (20%).
• Moderate: Albania (20%), Argentina (21%), Australia (10% GST), Austria (20%), Azerbaijan (18%), Belgium (21%), Bulgaria (20%), Cambodia (10%), Canada (5-15% GST/HST, plus PST 0-9.975%), Colombia (19%), Costa Rica (13%), Cyprus (19%), Czech Republic (21%), Dominican Republic (18%), Ecuador (13-15%), Egypt (14%), El Salvador (13%), Estonia (20%), France (20%), Gabon (18%), Georgia (18%), Germany (19%), Ghana (15%), Guatemala (12%), Honduras (15%), India (various, 5-28%), Indonesia (11%), Israel (17%), Italy (22%), Jamaica (15%), Japan (10%), Jordan (16%), Kazakhstan (12%), Kenya (16%), Korea (South) (10%), Kuwait (None), Lebanon (11%), Luxembourg (17%), Malaysia (0%), Mexico (16%), Mozambique (17%), Myanmar (CT 0-10%), Netherlands (21%), New Zealand (15% GST), Nigeria (7.5%), Pakistan (18%), Panama (7%), Peru (18%), Philippines (12%), Puerto Rico (10.5%), Qatar (None), Romania (19%), Russian Federation (20%), Saudi Arabia (15%), Serbia (20%), Singapore (9% GST), Slovakia (20%), Slovenia (22%), South Africa (15%), Spain (21%), Sri Lanka (8% VAT, 2% ESC), Switzerland (8.1%), Taiwan (5%), Tanzania (18%), Thailand (7%), Tunisia (19%), Turkey (20%), Uganda (18%), UAE (5%), Venezuela (16%), Vietnam (10%).
• Low: Canada (5-15% GST/HST), Myanmar (0-10% Commercial Tax), Panama (7% ITBMS), Taiwan (5%), Thailand (7%), UAE (5%).
• Zero-rated/Exempt Activities: Common exemptions include healthcare, education, financial services, exports, and real estate (e.g., Australia, Belgium, Brazil, Bulgaria, Cambodia, Canada, Costa Rica, Croatia, Cyprus, Czech Republic, Denmark, Ecuador, Egypt, El Salvador, Estonia, Finland, France, Germany, Ghana, Greece, Guatemala, Honduras, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Russian Federation, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Other Indirect Taxes:Stamp Duty: Widely imposed on various documents and transactions (e.g., Australia, Brazil, Brunei Darussalam, Cambodia, Costa Rica, Croatia, Cyprus, Dominican Republic, Ecuador, Egypt, El Salvador, Fiji, Finland, France, Germany, Ghana, Greece, Guyana, Hong Kong SAR, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Russian Federation, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Real Property Taxes: Common, often locally determined or based on property value (e.g., Australia, Belgium, Brazil, Bulgaria, Cambodia, Colombia, Costa Rica, Croatia, Cyprus, Czech Republic, Denmark, Dominican Republic, Ecuador, Egypt, El Salvador, Estonia, Finland, France, Germany, Ghana, Greece, Guatemala, Honduras, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Puerto Rico, Russian Federation, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Payroll Taxes/Social Security: Employer and employee contributions are mandatory in most countries (e.g., Argentina, Australia, Austria, Belgium, Brazil, Bulgaria, Canada, Colombia, Costa Rica, Croatia, Czech Republic, Denmark, Dominican Republic, Ecuador, Egypt, El Salvador, Estonia, Finland, France, Germany, Ghana, Greece, Guatemala, Honduras, Hungary, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Philippines, Poland, Portugal, Russian Federation, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Digital Services Tax (DST): Emerging in response to digital economy (e.g., Italy 3%).

7. Key Emerging Themes and Important Ideas

• BEPS 2.0 Pillar Two Implementation:
• Several countries are actively implementing or planning to implement Pillar Two rules (Global Minimum Tax of 15% for MNEs with turnover > EUR750 million). Examples include Australia (IIR from Jan 2024, QDMTT from Jan 2024, UTPR from Jan 2025), Bahamas (proposed QDMTT at 15%), Belgium (QDMDT and IIR from Jan 2024, UTPR from Jan 2025), Bulgaria (Primary additional tax from Jan 2024, Secondary additional tax from Jan 2025), Canada (IIR and domestic minimum top-up tax from Dec 2023, UTPR from Dec 2024), and Cyprus (Pillar Two rules to introduce 15% ETR).
• This indicates a global shift towards a more harmonized and minimum corporate tax rate for large multinational groups, designed to counter base erosion and profit shifting.
• Transfer Pricing & Arm’s Length Principle:
• Strict adherence to the arm’s-length principle is a universal requirement for related-party transactions. Most countries explicitly state that transactions between associated enterprises must be conducted at arm’s length (e.g., Australia, Azerbaijan, Belgium, Brazil, Bulgaria, Canada, Chad, Chile, China Mainland, Colombia, Congo, DR, Congo, Rep. of, Costa Rica, Croatia, Czech Republic, Denmark, Dominican Republic, Ecuador, Egypt, El Salvador, Estonia, Finland, France, Gabon, Germany, Ghana, Greece, Guatemala, Honduras, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Kenya, Korea (South), Lebanon, Luxembourg, Malaysia, Mexico, Mozambique, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Russian Federation, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Uganda, UK, Venezuela, Vietnam).
• Detailed transfer pricing methodologies, procedures, and documentation requirements are increasingly common (e.g., Australia (PCGs, risk ratings), Brazil (new OECD-aligned rules), China Mainland (Master File, Local File, CbCR), Colombia (thresholds, studies), Denmark (documentation for non-insignificant transactions), Egypt (filing thresholds), France (documentation on request, CbCR), Germany (documentation at audit, CbCR), India (APA program, rollback mechanism), Indonesia (various methods), Ireland (formal statutory regime), Italy (Masterfile, Country-Specific Documentation, electronic signature), Japan (thin-capitalization, earnings-stripping), Korea (South) (APA program), Netherlands (arm’s-length funding arrangements), Nigeria (APA program), Pakistan (CbCR), Peru (CbCR), Philippines (documentation), Poland (documentation), Portugal (documentation), Russian Federation (CbCR), Saudi Arabia (arm’s length), Singapore (documentation, APAs), South Africa (documentation, APAs), Spain (documentation, APAs), Sweden (documentation), Switzerland (documentation, APAs), Taiwan (documentation), Thailand (documentation), Turkey (documentation), UK (documentation, APAs), Venezuela (OECD guidelines), Vietnam (documentation, APAs)).
• Penalties for non-compliance with transfer pricing rules and documentation are significant (e.g., Australia, China Mainland, Denmark, Egypt, France, Germany, Indonesia, Israel).
• Hybrid Mismatch Rules:
• Many jurisdictions are implementing rules consistent with BEPS Action 2 to neutralize hybrid mismatch arrangements (e.g., Australia (from Jan 2019), Austria (from Jan 2020), Belgium (from Jan 2020), Canada (two legislative packages from July 2022 and 2023), Finland (from Jan 2020), Germany (deduction/no inclusion, double deduction, imported mismatches), Ireland (from Jan 2020), Israel).
• This targets situations where differences in tax treatment of entities or instruments across countries lead to double non-taxation or double deductions.
• Controlled Foreign Corporation (CFC) Rules:
• CFC rules are widely adopted to prevent income deferral strategies by shifting profits to low-tax jurisdictions (e.g., Australia, Austria, Belgium, Canada, Chile, China Mainland, Colombia, Denmark, Finland, Germany, Greece, Ireland, Israel, Italy, Japan, Luxembourg, Netherlands, New Zealand, Philippines, Portugal, Russian Federation, Slovenia, South Africa, Spain, Sweden, UK, US, Venezuela).
• These rules often involve taxing the parent company on a portion of the CFC’s undistributed passive income, subject to various conditions (e.g., effective tax rate thresholds, genuine economic activity tests).
• Digitalization of Tax Administrations:
• Growing emphasis on electronic filing, digital services, and automatic exchange of information (e.g., Albania (e-declaration for TP), Australia (ATO New Investment Engagement Service), Belgium (digital reporting of cross-border payments), China Mainland (e-invoicing pilot), Colombia (e-invoicing), Costa Rica (web-based platform for large taxpayers), Cyprus (electronic VAT refund claims), Dominican Republic (e-filing), Ecuador (digital services VAT), Egypt (e-invoicing), Estonia (electronic VAT refund claims), Finland (e-invoicing), France (e-invoicing), Germany (e-invoicing), Greece (e-books, e-invoicing), Hungary (online invoice data reporting), India (e-invoicing, e-assessment), Indonesia (e-filing), Ireland (online filing), Italy (e-invoicing, e-filing), Japan (e-tax system), Jordan (e-filing), Kazakhstan (e-filing), Kenya (e-T.R.A.P.S), Korea (South) (e-filing), Lebanon (e-filing), Luxembourg (e-filing for VAT refunds), Malaysia (e-filing), Mexico (e-invoices), Myanmar (e-tax), Netherlands (e-filing), New Zealand (e-filing), Nigeria (e-filing), Norway (e-filing), Pakistan (e-filing), Peru (e-filing), Philippines (e-filing), Poland (e-filing), Portugal (e-filing), Puerto Rico (e-filing), Romania (e-filing), Russian Federation (e-filing), Saudi Arabia (e-filing), Serbia (e-filing), Singapore (e-filing), Slovakia (e-filing), Slovenia (e-filing), South Africa (e-filing), Spain (e-filing), Sri Lanka (e-filing), Sweden (e-filing), Switzerland (e-filing), Taiwan (e-filing), Tanzania (e-filing), Thailand (e-filing), Tunisia (e-filing), Turkey (e-filing), Uganda (e-filing), UK (digital links, MTD), US (e-filing), Venezuela (e-filing), Vietnam (e-invoicing)).
• This trend aims to enhance tax compliance, efficiency, and transparency.
• Economic Substance Requirements (ESR):
• Jurisdictions that historically offered low or no tax regimes are increasingly implementing ESR to prevent artificial profit shifting and meet international standards (e.g., Aruba, Bahamas, Bahrain, British Virgin Islands, Cayman Islands, Guernsey, Isle of Man, Jersey).
• These requirements often mandate adequate local expenditure, employees, physical offices, and core income-generating activities within the jurisdiction.
• Anti-Avoidance Legislation:
• General anti-avoidance rules (GAARs) and specific anti-abuse provisions are common to counter tax fraud, treaty shopping, and other aggressive tax planning (e.g., Australia (Part IVA, DPT), Belgium (“abnormal and gratuitous advantages”, tax havens reporting), Canada (GAAR), Croatia (prohibited list jurisdictions), Cyprus (general anti-abuse provisions for reorganizations), Czech Republic (transactions lacking economic substance), Finland (general anti-avoidance provision, anti-hybrid mismatch rules), France (profits transferred indirectly, uncooperative countries list), Germany (treaty/directive shopping, Anti-Tax Haven Act), Greece (CFC rules, transfers of operations), India (GAAR, anti-abuse rule for indirect transfers), Ireland (interest deduction restrictions, CFC rules, transfer pricing), Israel (CFC rules, anti-abuse for capital losses), Italy (abuse of law definition), Japan (anti-avoidance for capital losses), Netherlands (anti-abuse for interest deduction), New Zealand (related party capital gains), Peru (tax havens), Philippines (tax havens), Portugal (beneficiary not the beneficial owner), Russian Federation (CFC rules), Saudi Arabia (tax havens), Singapore (GAAR), Slovakia (tax havens), Slovenia (CFC rules), South Africa (GAAR), Spain (abuse of law), Sweden (anti-avoidance), Switzerland (anti-abuse for tax relief), Taiwan (CFC rules), Tanzania (AMT), Thailand (transfer pricing), Tunisia (tax havens), Turkey (anti-avoidance for related parties), Uganda (anti-avoidance for related parties), UK (GAAR), US (transfer pricing), Venezuela (transfer pricing), Vietnam (tax havens)).
• Environmental and Green Incentives:
• A growing number of countries are introducing tax incentives for investments in environmental protection, energy efficiency, and green industries (e.g., France (green industry credit), Hungary (energy efficiency allowance), Japan (greenhouse gas reduction facilities)).
• This reflects a global trend towards leveraging tax policy to support sustainability goals.

8. Important Facts and Figures

• Angola: Minimum capital for a Limited Company (SA) is Kwanza equivalent of US $20,000. Corporate tax rate for national oil companies, banks, insurance companies, and telecom operators is 35%.
• Argentina: Corporate tax for 2024 is progressive from 25% to 35%, based on indexed annual income thresholds. Capital gains from unlisted shares by foreign residents are 15% (or 13.5% effective on presumed 90% income). Interest deductibility from related parties limited to 30% of EBITDA, with carryforward for 5 years. Double Taxation Treaties not currently effective as terminated by Argentine Government in 2012 or prior year.
• Australia: Corporate tax rate is 30% (27.5% for small business entities in 2016-17, increasing to $25m turnover for 2017-18). Tax year is July 1 to June 30. Capital gains taxable at regular corporate tax rate (no concessions as for individuals). GST is 10%. Proposed Pillar Two rules for MNEs with turnover > EUR750 million (IIR from 2024, QDMTT from 2024, UTPR from 2025).
• Austria: Top individual tax rate 55% for income over €1,000,000. Corporate tax rate reduced to 23%. Withholding tax rate for dividends 27.5% (23% for corporate investors). Loss carryforward unlimited for Austrian trade losses.
• Azerbaijan: Corporate profit tax rate is 20%. Advance payments of corporate profit tax by 15th day following end of each quarter.
• Barbados: No capital gains taxes. Basic personal amount tax-free: $25,000.
• Belgium: Standard corporate tax rate is 25%. Standard WHT for dividends and interest is 30%. Notional interest deduction (NID) regime abolished for tax periods ending on or after 31 Dec 2023. VAT standard rate 21%. Loss carryforward unlimited.
• Brazil: Corporate tax rate (CIT + surtax + SCT) is generally 34%. Inheritance tax 4% in São Paulo. Provisional Measure No. 1,152 (PM 1,152) introduces new OECD-aligned transfer-pricing rules.
• Bulgaria: Corporate income tax rate is 10%. VAT standard rate 20%. Minimum capital for OOD (LLC) is BGN 2 (EUR 1), for AD (PLC) is BGN 50,000 (EUR 25,565).
• Cambodia: Corporate tax (ToI) is 20% for most entities under the Real Regime Tax System (RRTS). WHT on dividends to non-residents is 14%. Capital gains are generally treated as ordinary income and taxed at the ToI rate, with no separate CGT prior to Jan 1, 2025.
• Canada: Corporate tax rates vary by federal and provincial governments. Capital gains inclusion rate will increase from 50% to 66 2/3% for gains/losses realized on or after June 25, 2024. WHT on branch tax is 25% (reducible by treaty). Pillar Two rules implementing IIR and domestic minimum top-up tax from Dec 2023, UTPR from Dec 2024.
• Cayman Islands: No taxes on income, profits, wealth, or capital gains. Economic substance requirements effective from Jan 1, 2019.
• Chad: Standard corporate income tax rate is 30%. Minimum tax is 2% of turnover, paid monthly. WHT on dividends to non-residents is 18%.
• Chile: Corporate tax rate is 27%. WHT on dividends to non-residents is 35%, with a credit for up to 100% of corporate tax paid by the Chilean company. Reduced 4% WHT for certain interest payments.
• China Mainland: Standard corporate income tax rate is 25%. WHT on dividends for non-residents is 10%. Net operating loss carryforward can be extended to 10 years for qualifying HNTEs and technology-based SMEs. VAT standard rate 13%. Transfer pricing documentation requirements are detailed, with penalties for non-compliance. CFC rules apply if effective tax rate < 12.5%.
• Colombia: Corporate tax rate is 35%. Equity Tax applies to individuals/non-residents with net equity > 72,000 UVT. Debit tax (financial transactions tax) 0.4%. Significant Economic Presence (SEP) rules from 2024 for non-residents (10% WHT or 3% over gross income). Debt-to-equity ratio for related-party loans is 2:1.
• Congo, DR: Corporate income tax rate is 30%. WHT on dividends is 20% (10% for mining companies).
• Congo, Rep. of: Corporate income tax rate is 30%. Special tax of 20% on capital gains for non-residents selling shares in Congolese companies.
• Costa Rica: Corporate income tax rate is 30% (25% for companies with sales <= USD150,000). Capital Gains Tax at 15%. VAT 13%.
• Croatia: Corporate income tax rate 18% (10% for income < €1,000,000). VAT standard rate 25%.
• Cyprus: Corporate income tax rate 12.5%. “Profi t on the sale of ‘titles’ (ie shares, bonds, options…)” is unconditionally tax exempt. 80% of net royalty income/gain on disposal of IPs is tax exempt (effective 2.5% rate). VAT standard rate 19%. Pillar Two rules for MNEs with turnover > EUR750 million.
• Czech Republic: Standard corporate income tax rate 21%. WHT on dividends is 15% (exempt under EU Parent-Subsidiary Directive). VAT standard rate 21%. Loss carryforward of 5 years, carryback up to CZK30 million.
• Denmark: Corporate tax rate 22%. WHT on dividends paid is 27% (5% refundable, effectively 22%). VAT standard rate 25%. CFC rules apply.
• Dominican Republic: Corporate tax rate 27%. WHT on dividends is 27%. Transfer pricing regulations based on arm’s length principle.
• Ecuador: Corporate income tax 25% (30% for over USD150,000 turnover). VAT 13-15%. Remittance Tax (RT) 5%.
• Egypt: Corporate income tax 22.5%. Transfer pricing documentation required if aggregate related-party transactions exceed EGP15 million.
• El Salvador: Corporate income tax 30% (25% for sales <= USD150,000). CGT 10% (25-30% if sold within 12 months).
• Estonia: Companies are subject to 20% corporate income tax on distributed profits. Dividends received are not included in taxable income. VAT standard rate 20%.
• Finland: Corporate tax rate 20%. CGT for private equity investors is taxable. Interest limitation rules apply. CFC rules apply if effective tax rate is less than three-fifths of Finnish CIT rate.
• France: Corporate income tax rate 25%. Capital gains on qualifying participations 12% (effective 3% on 25% CIT rate). Reduced 10% rate for net income from licensing qualifying patents or software. VAT standard rate 20%.
• French Polynesia: No individual income tax, only a Solidarity Tax (CST). Corporate income tax (IS) standard rate between 25% and 35%.
• Gabon: Corporate income tax 30% (35% for oil/gas/mining). WHT on dividends 10/20%. Loss carryforward 5 years.
• Germany: Corporate income tax 15% (plus solidarity surcharge and trade tax). Capital gains on sales of shares in corporations 95% exempt. VAT standard rate 19%. Anti-hybrid rules, interest barrier rules, and CFC rules are in place.
• Ghana: Standard corporate income tax rate 25%. WHT on non-traditional exports is 8%. VAT standard rate 15%. Depreciation rates vary by asset class (e.g., 40% for computers, 10% for buildings).
• Greece: Corporate income tax rate 22% (29% for credit institutions). WHT on dividends 5%. VAT standard rate 24%. Interest deductibility limited to 30% of tax EBITDA. CFC rules apply.
• Guatemala: Corporate income tax 25%. WHT on dividends 5%. No foreign exchange controls.
• Guernsey: No capital gains tax. Corporate income tax 0%. WHT on dividends, interest, royalties is Nil.
• Guyana: Corporate tax rate 40% (45% for telephone companies, 25% for non-commercial companies). WHT on dividends to non-residents 20%. Loss carryforward unlimited.
• Honduras: Income tax 25% (plus 5% solidarity tax on excess of HNL1m). VAT 15%. CGT 10%. No double tax treaties.
• Hungary: Corporate tax rate 9%. Losses incurred in 2015+ carryforward for 5 years, up to 50% of tax base. Capital gains from sale of “reported shares” are exempt. VAT 27%.
• India: Corporate tax 30% (concessional rates for new/qualifying manufacturing companies). Minimum Alternative Tax (MAT) 15% of book profit. WHT on dividends 20%. CGT on transfer of listed securities at 15% for short-term. Transfer pricing documentation, APA program, and rollback mechanism in place.
• Indonesia: Corporate income tax 25% (20% for public companies, 1% for small enterprises). WHT for dividends 15% for corporations, 10% for individuals (final). VAT 11%. Debt-to-equity ratio maximum 4:1.
• Iraq: Corporate income tax 15% (35% for oil/gas/mining). WHT varies. Loss carryforward 5 years.
• Ireland: Corporation tax 12.5% for trading income, 25% for passive income. CGT applies to development land and shares deriving value from it. R&D tax credit 25%. Digital gaming credit 32%. Anti-avoidance measures apply to outbound payments.
• Isle of Man: Standard corporate income tax rate 0% (10-15% for banking/retail, 20% for land/property income). No WHT on dividends, interest, royalties generally. Economic substance requirements.
• Israel: Corporate income tax 23%. Reduced 6% rate for IP-based income and capital gains from IP sales for qualifying companies. WHT on dividends 25-30%. CFC rules.
• Italy: Corporate income tax (IRES) 24%. Regional tax on productive activities (IRAP) standard rate 3.9%. WHT on loan interest 26%, royalties 30% (effective 22.5%). Digital Services Tax (DST) 3%. Patent Box regime provides super deduction for R&D expenses. Anti-hybrid and CFC rules in place.
• Jamaica: Corporate income tax 25% (special rates for SEZ, specific sectors). WHT on dividends to non-residents 33⅓%.
• Japan: National corporation tax 23.2% (15% for small corporations). Earned profits tax for closely held corporations (10/15/20%). Loss carryforward 10 years for net operating losses, 3 years for some capital losses. Thin-capitalization (3:1 debt-to-equity) and earnings-stripping rules (20% adjusted taxable income).
• Jordan: Corporate income tax 20-30% plus national contribution (1-7%). WHT on interest 7% for banks, 5% for individuals, 10% for non-depository. WHT on royalties 10%.
• Kazakhstan: Corporate income tax 20%. VAT 12%. Loss carryforward 10 years.
• Kenya: Corporate tax 30%. WHT on dividends to non-residents 15%. CGT 15%.
• Korea (South): Corporate tax 10-24% progressive (plus 10% local income surtax). CGT 6-70% on land/buildings, 10-30% on shares. Inheritance tax on property acquired on death.
• Kuwait: No VAT. Zakat tax 1% on Kuwaiti shareholding companies. Real Property Tax 0.5%.
• Lebanon: Corporate income tax 15%. WHT on dividends 10%. VAT 11%. NSSF employer contribution 6% for family allowances, 7% for health, 8.5% for end of service.
• Liechtenstein: Corporate income tax 12.5% (minimum CHF1,800). WHT on dividends 0%. No asset tax for general/limited partnerships if domicile of individual is abroad and no PE.
• Luxembourg: Corporate income tax 17% (total 22.8% with municipal business tax and solidarity surcharge). WHT on dividends 15%. VAT standard rate 17%.
• Malaysia: Corporate tax rate 24%. WHT on dividends 0%. Loss carryforward up to 7 years.
• Mexico: Corporate tax 30%. VAT 16%. No CGT as such, but profits from asset sales included in taxable income.
• Morocco: Corporate tax rates 10-31% progressive. Loss carryforward 4 years.
• Mozambique: Corporate income tax 32%. Thin capitalization rules (debt-to-equity > 2:1). WHT on dividends 20%. VAT 17%.
• Myanmar: Corporate income tax 25%. Commercial Tax (CT) is a turnover tax (0-10%). Foreign companies prohibited from owning immovable property.
• Netherlands: Corporate income tax 15-25% progressive. WHT on dividends 15%. VAT standard rate 21%. CFC rules.
• New Zealand: Corporate income tax 28%. No CGT, but certain land/foreign investment gains taxable. GST 15%.
• Nigeria: Corporate income tax 30%. VAT 7.5%. WHT on dividends, interest, royalties 10% (7.5% for treaty countries).
• Norway: Corporate income tax 22%. WHT on dividends 25%. VAT standard rate 25%. Loss carryforward unlimited.
• Pakistan: Corporate income tax 29%. VAT 18%. Capital gains on immovable property 15-29%.
• Panama: Corporate income tax 25%. WHT on dividends 10-20%. ITBMS (VAT) 7%.
• Peru: Corporate income tax 26-28% (decreasing over time). VAT 18%.
• Philippines: Corporate income tax 20-30%. VAT 12%.
• Poland: Corporate income tax 19%. VAT standard rate 23%.
• Portugal: Corporate income tax 21%. WHT on dividends 25%. CGT on shares/bonds 28% flat. Stamp Tax on inheritance/gifts 10%.
• Puerto Rico: Corporate Income Tax 20-37.5%. VAT 10.5%. “Export Services Act 20” provides tax benefits.
• Romania: Corporate income tax 16%. No CGT. VAT 19%.
• Russian Federation: Corporate income tax 20%. WHT on dividends 15%. NDFL (PIT) 13% for residents, 30% for non-residents.
• Saudi Arabia: No corporate income tax for Saudi residents. 20% corporate tax on foreign companies. VAT 15%.
• Serbia: Corporate income tax 15%. VAT standard rate 20%.
• Singapore: Corporate income tax 17%. WHT on dividends 0%. GST 9%.
• Slovakia: Corporate income tax 21%. VAT standard rate 20%.
• Slovenia: Corporate income tax 19%. VAT standard rate 22%.
• South Africa: Corporate income tax 27% from 2023. VAT 15%. CGT on worldwide assets at 40% inclusion rate (effective 8% for companies).
• Spain: Corporate income tax 25%. VAT standard rate 21%.
• Sri Lanka: Corporate income tax 24%. VAT 8%. ESC (Economic Service Charge) 0.25% on turnover.
• Sweden: Corporate income tax 20.6%. VAT standard rate 25%. No inheritance tax.
• Switzerland: Federal income tax 8.5%, cantonal/municipal taxes vary (average 11.9% to 21%). VAT standard rate 8.1%.
• Taiwan: Corporate income tax 17% (0% for under NT$120,000). VAT 5%.
• Tanzania: Corporate income tax 30%. VAT 18%. WHT on dividends 15%.
• Thailand: Corporate income tax 20% (lower for small companies). VAT 7%.
• Tunisia: Corporate income tax 15-35%. VAT 19%.
• Turkey: Corporate income tax 25%. VAT 20%. Individual income tax 15-35%.
• Uganda: Corporate income tax 30%. VAT 18%. WHT on dividends, interest, royalties 15%.
• UK: Corporation tax 25%. VAT standard rate 20%. IHT 40%.
• Venezuela: Corporate income tax 15-50%. VAT 16%. Transfer pricing rules based on OECD guidelines.
• Vietnam: Corporate income tax 20%. VAT 10%. PIT progressive rates.

Top 5 Best Tax Jurisdictions ranked on the basis of low tax rates:

Based on the above information, here are the top 5 tax jurisdictions that appear to offer the most favourable tax regimes, generally characterised by low or zero Corporate Income Tax (CIT) rates, Capital Gains Tax (CGT), and withholding taxes (WHT) on dividends, interest, and royalties:

1. Isle of Man

    ◦ Resident Corporate Income Tax Rate: 0%.

    ◦ Capital Gains Tax Rate: 0%.

    ◦ Withholding Tax (Dividends): 0%.

    ◦ Withholding Tax (Interest): 0%.

    ◦ Withholding Tax (Royalties): 0%.

    ◦ The Isle of Man stands out for having a 0% rate across all these major tax categories for resident corporations.

2. Jersey, Channel Islands

    ◦ Corporate Income Tax Rate: Generally 0%. However, a 10% rate applies to certain regulated financial services companies, and a 20% rate applies to utility companies, companies involved in the importation and supply of hydrocarbon oil to Jersey, companies in the cannabis industry, and rental income, development profits, and certain income derived from Jersey land.

    ◦ Withholding Taxes (Dividends, Interest, Royalties): There are no withholding taxes under Jersey Law.

    ◦ Jersey offers a very attractive 0% general corporate income tax rate and no withholding taxes on these payments.

3. Guernsey

    ◦ Corporate Income Tax Rate: Generally 0%. A 10% rate applies to certain regulated financial services, and a 20% rate applies to utility companies, companies involved in the importation and supply of hydrocarbon oil or gas in Guernsey, companies in the cannabis industry, and large retail businesses in Guernsey with taxable profits over GBP500,000. Exempt company regimes for collective investment schemes are also available, with an annual fee of GBP1,600.

    ◦ Withholding Taxes (Dividends, Interest, Royalties): Nil.

    ◦ Guernsey is another highly favourable jurisdiction, providing a 0% general corporate income tax rate and no withholding taxes on dividends, interest, and royalties.

4. BES-Islands (Bonaire, Sint Eustatius and Saba)

    ◦ Profit Tax: The tax regime in the BES-Islands does not include a profit tax.

    ◦ Yield Tax: A 5% yield tax is levied on distributions of profits by entities resident in the BES-Islands.

    ◦ Withholding Tax (Interest & Royalties): Interest and royalty payments are not subject to the yield tax.

    ◦ Branch Remittance Tax: The yield tax is not levied on the remittances of profits by branches to their foreign head offices.

    ◦ While there is a 5% yield tax on distributed profits, the absence of a general profit tax and no withholding tax on interest, royalties, or branch remittances makes it a very attractive jurisdiction.

5. Saudi Arabia

    ◦ Corporate Income Tax Rate: None (implied by the absence of a general rate in the “At a glance” table and “None” for specific tax categories in the source).

    ◦ Capital Gains Tax Rate: None (implied by the absence of a general rate in the “At a glance” table and “None” for specific tax categories in the source).

    ◦ Inheritance Tax: None.

    ◦ Value-Added Tax (VAT): Nil.

    ◦ Withholding Tax (Dividends): 5%.

    ◦ Withholding Tax (Interest): 5%.

    ◦ Withholding Tax (Royalties): Varies; 5% for rents, services, and insurance, but can be higher (20% for management fees, 15% for transactions to a head office or related parties abroad, 15% for any other payments).

    ◦ Saudi Arabia stands out for its absence of general corporate income tax, capital gains tax, inheritance tax, and VAT. While withholding taxes apply to dividends and interest at 5%, and royalties can be higher depending on the nature of the payment, the overall tax burden for many activities is exceptionally low