Sociedad Anónima (Corporation) and SRL (LLC)

An SA, same as an SRL (LLC), is considered an Argentine resident for tax purposes and is obligated to pay taxes on income obtained worldwide, whether earned within Argentina or abroad. An SA may take the sums effectively paid abroad for analogous taxes for activities carried out abroad as a payment for taxes (within certain limits).

Branch

A foreign company is taxed as a separate entity in Australia and taxed on all income sourced from Australia. As the foreign company is carrying on an enterprise in Australia, it will also be required to register for Goods and Services Tax (GST).

Proprietary company

The company is taxed at a fixed rate on its income and capital gains. Profits are usually distributed by way of dividend. Dividends may be "franked" in effect to give Australian tax resident recipient shareholders a credit for the tax paid by the company.

Public company

The company is taxed at a fixed rate on its income and capital gains. Profits are usually distributed by way of dividend. Dividends may be "franked" in effect to give Australian tax resident recipient shareholders a credit for the tax paid by the company.

Limited Liability Company and Stock Corporation

AG and GmbH are taxed at 2 levels. First, the company/corporation pays a corporate income tax on its corporate income; then, the company/corporation distributes profits to stockholders, who are then taxed with income tax (withholding tax).

General Partnership and Limited Partnership

OG and KG are treated as being transparent for income tax purposes as there is only 1 level of taxation. The corporate profits "pass through" to the owners, who pay taxes on the profits at their individual tax rates.

• No personal income tax or corporate taxes payable.
• A corporate tax of 46 percent is imposed on oil, gas and related companies.
• As of January 1, 2022, Bahrain has increased value added tax (VAT) to a standard rate of 10 percent. Some suppliers, however, are exempt or zero-rated. VAT generally applies on the supply of goods and services by domestic taxpayers as well as on the import of such goods and services. Under certain circumstances, foreign businesses with supplies in Bahrain may also fall within the scope of VAT.

Public limited company (société anonyme/naamloze vennootschap)

Subject to corporate income tax:

• Belgian public limited companies are in principle taxable on their worldwide income, less allowable deductions. The taxable income is determined on the basis of the approved Belgian GAAP annual accounts, subject to certain adjustments in accordance with the Belgian Income Tax Code

• Resident public limited companies are subject to a standard corporate income tax rate of 25 percent. The first income band of EUR 100,000 of small public limited companies is subject to a lower rate of 20 percent provided that certain conditions are met

• A participation exemption regime exists for received dividends under which, subject to certain conditions, 100 percent of the received dividends are deductible. Capital gains realized on shares may be exempt provided that certain conditions are met
• The payment of dividends, royalties and interest is in principle subject to a 30-percent withholding tax. Domestic law provides for reduced rates and exemptions in certain circumstances. The applicable rate may further also be reduced under an applicable double taxation treaty

• Losses may in principle be carried forward indefinitely, but their use in a given tax year is limited to EUR 1 million plus 70 percent of the taxable basis in excess of EUR 1 million. As of income year 2023 (assessment year 2024), the 70-percent threshold has been reduced to 40 percent, to increase the minimal taxable basis to 60 percent instead of 30 percent. This measure is temporary, as it is the intention to abolish this measure as soon as the global minimum tax rules (OECD Pillar Two) enter into force in Belgium.

• A CFC regime and a group consolidation regime entered into force in 2019

Limited company (société à responsabilité limitée/besloten vennootschap)

Subject to corporate income tax:

• Belgian limited companies are in principle taxable on their worldwide income, less allowable deductions. The taxable income is determined on the basis of the approved Belgian GAAP annual accounts, subject to certain adjustments in accordance with the Belgian Income Tax Code

• Resident limited companies are subject to a standard corporate income tax rate of 25 percent. The first income band of EUR 100,000 of small limited companies is subject to a lower rate of 20 percent provided that certain conditions are met

• A participation exemption regime exists for received dividends under which, subject to certain conditions, 100 percent of the received dividends are deductible. Capital gains realized on shares can be exempt provided that certain conditions are met
• The payment of dividends, royalties and interest is, in principle, subject to a 30-percent withholding tax. Domestic law provides for reduced rates and exemptions in certain circumstances. The applicable rate may further also be reduced under an applicable double taxation treaty
• Losses may in principle be carried forward indefinitely, but their use in a given tax year is limited to EUR 1 million plus 70 percent of the taxable basis in excess of EUR 1 million. As of income year 2023 (assessment year 2024), the 70-percent threshold has been reduced to 40 percent, to increase the minimal taxable basis to 60 percent instead of 30 percent. This measure is temporary, as it is the intention to abolish this measure as soon as the global minimum tax rules (OECD Pillar Two) enter into force in Belgium.
• A CFC regime and a group consolidation regime are included in Belgian tax law

Belgian branch office of a foreign company

A Belgian branch office of a foreign company will, in principle, be subject to tax on income generated by the Belgian branch office and will thus be subject to the so-called corporate nonresident income tax. Under the corporate nonresident income tax, specific categories of Belgian-sourced income are subject to tax. The nonresident income tax that is due is, in principle, calculated based on the corporate income tax rules for resident companies. Hence, the alternative implementation of the global minimum tax rules, in anticipation of the implementation of OECD Pillar Two, will also be applicable to the Belgian branch office of a foreign company. In addition, the applicable tax rates are identical to the tax rates for resident companies. If a double taxation treaty is in place between Belgium and the state of tax residence of the foreign company, such treaty should be consulted in order to verify whether Belgium has the authority to tax the income that is attributable to the branch.

The foreign company (via its branch office) may also be subject to certain other possible taxes, such as registration taxes on the purchase of real estate or communal taxes.

Depending on its activities, the Belgian branch office may also qualify as VAT taxpayer.

Limited liability company (Sociedade Limitada)

A legal entity incorporated in Brazil is treated as a domestic legal entity for tax purposes, and is subject to Brazilian income tax on its worldwide income.

Corporation (Sociedade Anônima)

A legal entity incorporated in Brazil is treated as a domestic legal entity for tax purposes, and is subject to Brazilian income tax on its worldwide income.

Corporate subsidiary (Corporation form rather than flow-through form) 

Canadian resident corporations are subject to federal and provincial/territorial corporate tax on worldwide income. Corporations are not subject to "branch profits tax" but are required to pay withholding tax on dividends and certain other amounts paid or distributed to non-Canadian resident shareholders, the rate of which varies depending upon the existence of a tax treaty between Canada and the shareholder's country of residence. This "dual layer of tax" (ie, first at the corporate level and then again upon distribution at the shareholder level) is sometimes referred to as double taxation. Share capital, however, can generally be repatriated free of any Canadian withholding tax (without first distributing E&P).

The Chilean tax regime levies taxes at 2 levels. First, the company pays a corporate tax on its income. Then, stockholders pay a personal tax on dividends. The structure of the general tax regime is the following:

Corporate income tax is paid by the entity on its income and is payable on an accrued basis. Shareholders or equity holders must pay final taxes on actual distributions. The general tax regime, with a rate of 25 percent (also known as the "Pro Pyme" regime), allows taxpayers who own shares or participations in the first-category taxpayer entities to credit 100 percent of the corporate tax against their final taxes, without restitution of credits. However, this regime is limited by the initial capital, which may not exceed UF85,000 (Unidades de Fomento), equivalent to USD3.6 million, and by the total income of the group, which may not exceed an average of UF75,000 (USD3.2 million) over the last three years.

If these limits are exceeded, the shareholders or holders of participations must apply the partially integrated regime, in which, at a rate of 27 percent, they are entitled to credit 100 percent of the corporate income tax paid by the company against the final taxes, with the obligation to refund 35 percent of this credit.

An LLC is taxed at 2 levels (commonly referred to as double taxation). First, the LLC pays an enterprise income tax on its corporate income; then, the LLC distributes its after-tax profits as dividends to shareholders who then pay individual/enterprise income tax on those dividends.

At a corporate level, all entities are taxed based on their earnings. At a personal level, partners and shareholders are taxed based on distributed dividends.

A stock corporation or limited liability company is taxed at 2 levels: First, the company pays a corporate income tax on its corporate income; then, a company distributes profits to shareholders, who then pay income tax on those dividends (to be withheld by the company upon payment).

Companies are obliged to add value-added tax (VAT) to the prices of their goods or services and to invoice their customers accordingly.

Limited liability company (Kapitalselskab)

The profits of a limited company are taxed at 2 levels (commonly referred to as double taxation). Firstly, the limited company pays a corporate tax on its corporate income. Limited companies are subject to a Danish corporate income tax rate, which currently amounts to 22 percent.

Secondly, the shareholders pay tax on the distributed profits from the limited company.

Corporations

• Corporate entity is subject to income tax at the rate of 22.5 percent of its annual net profits.
• Employees' salaries are subject to income tax.
• The company makes a withholding tax at the rate of 10 percent upon distribution of dividends. As an exception, shareholders or quotaholders who own 25 percent of the company's shares or quotas for at least 2 years are subject to a withholding tax at a rate of 5 percent.
• Corporate entities must make social insurance contributions from both employers and employees.
• Corporate entities, which sell goods or provide services that are subject to value-added tax (VAT) according to the VAT Law no. 67 of 2016, and whose annual turnover exceeds the amount of EGP500,000, must be registered with the Egyptian Tax Authorities (ETA) for VAT purposes. By way of exception to the abovementioned threshold, corporate entities may apply to be registered for VAT purposes even if their turnover does not exceed said threshold provided that:
  • Their annual turnover during the 12 months prior to filing the registration application must not be less than EGP150,000 or its paid-up capital must not be less than EGP50,000
  • They have registered physical office space through which they perform their registered activity and
  • They have a valid tax card.
• VAT at the rate of 14 percent, generally, is applied to all taxable local and imported goods and services, except:
  • Those specifically exempted by the VAT Law
  • Machinery and equipment used in the production of such goods and services which shall be levied at 5 percent and
  • All other products listed in the annex to the VAT Law which specifies the percentage of tax levied on them.

Branch

• A branch is subject to income tax at the rate of 22.5 percent of its annual net profits. Branch employees' salaries are subject to an income tax.
• The branch makes a withholding tax at the rate of 10 percent upon distribution of dividends and social insurance contributions from both the employers and employees.
• Branches, which sell goods or provide services subject to VAT and whose annual turnover exceeds the amount of EGP500,000, must be registered with the ETA for VAT purposes.
• VAT at the rate of 14 percent, generally, is applied to all taxable local and imported goods and services, except:
  
  • Those specifically exempted by the VAT Law
  • Machinery and equipment used in the production of such goods and services which shall be levied at 5 percent and
  • All other products listed in the annex to the VAT Law, which specifies the percentage of tax levied on them.

RO

An RO's employees are subject to income tax and social insurance contributions from both employers and employees.

Osakeyhtiö (Oy)

The profits of an Oy are taxed at 2 levels (commonly referred to as double taxation). First, the Oy pays a corporate tax on its corporate income; then shareholders pay tax on the distributed profits from the Oy. The Oy is subject to a Finnish corporate income tax rate, which currently amounts to 20 percent.

Société par actions simplifiée (SAS)

Are subject to French taxes, including corporate income tax (33 1/3 percent), withholding tax on profits and business tax as well as VAT.

Société à responsabilité limitée (SARL)

Are subject to French taxes, including corporate income tax (33 1/3 percent), withholding tax on profits and business tax as well as VAT.

Société anonyme (SA)

Are subject to French taxes, including corporate income tax (33 1/3 percent), withholding tax on profits and business tax as well as VAT.

GmbH – limited liability company

A GmbH is usually taxed on 2 levels:

• Firstly, it is subject to corporate income tax (Körperschaftsteuer).
• On the second level, a GmbH is subject to trade tax (Gewerbesteuer), which is imposed by local municipalities (ie, the town or city where the company is based).

Companies are obliged to add value-added tax (VAT – Mehrwertsteuer) to the prices of their goods or services and to invoice their customers accordingly.

Societe anonyme (S.A.)

The SA pays a corporate tax on its corporate income and then distributes dividends to shareholders who are taxed as well.

Limited liability company (L.T.D.)

Company pays a corporate tax on its corporate income and then distributes profits to partners. A tax of a specific rate is withheld for profits that are distributed by the company.

Private company (P.C.)

Company pays a corporate tax on its corporate income and then distributes profits to partners. A tax of a specific rate is withheld for profits that are distributed by the company.

Limited private companies

A limited private company is taxed on its business profits at a corporate level. There are no tax on capital gains or dividends except for certain foreign-sourced income pursuant to the new Foreign Source Income Exemption regime which came into effect on January 1, 2023.

Private company limited by shares (Zrt.)

A Zrt., as a Hungarian resident company, is taxed on its worldwide income subject to conditions of double tax treaty provisions. A company is resident if it has been incorporated in Hungary or has its place of effective management in Hungary.

Limited liability company (Kft.)

A Kft., as a Hungarian resident company, is taxed on its worldwide income subject to conditions of double tax treaty provisions. A company is a resident if it has been incorporated in Hungary or has its place of effective management in Hungary.

Private limited company

A private limited company is taxed at 2 levels. First, the company pays a corporate tax on its corporate income; then, the company pays dividend distribution tax on profits distributed to shareholders (declared prior to April 1, 2020). With effect from April 1, 2020, a dividend paid by an Indian company is taxable in the hands of the recipient shareholder.

Sale or redemption of shares in the company is taxed as capital gains. Any indirect transfer of India shares may trigger indirect transfer tax provisions.

Limited liability company

Corporate income tax is reduced from 22 percent to 20 percent as of the 2022 tax year and VAT of 11 percent is imposed on the delivery of goods and services and will be raised to 12 percent no later than January 1, 2025.

Private company limited by shares (LTD)

If an Irish tax resident, a LTD is subject to Irish corporation tax on its worldwide income at 12.5 percent on its trading income and 25 percent for non-trading (ie, passive) income.

If non-resident for Irish tax purposes, a LTD is not subject to Irish corporation tax unless it carries on a trade in Ireland through a branch or agency or if it receives income from Irish sources (eg, income from the rental of Irish properties).

External company

An Irish branch is subject to Irish corporation tax on:

• Trading income arising directly or indirectly through or from the branch
• Any income from property or rights used by, or held by or for, the branch and
• Chargeable gains accruing on the disposal of Irish land and any assets situated in Ireland which are used for the purposes of a trade carried on by the Irish branch or are held for the purposes of the branch.

Company

A company is taxed at 2 levels. First, the company pays a corporate tax on its corporate income; shareholders are then taxed on dividends distributed by the company (if distributed).

Branch / representative office

Only taxed at the corporate entity level on income.

Società a responsabilità limitata (S.r.l.)

Its earnings are taxed at a corporate level and quota-holders are taxed on any distributed dividends.

Registered branch

Income arising within Japan is, in principle, taxed, and income attributable to a branch arising in the countries other than Japan (if any) is subject to income tax in Japan.

Kabushiki-Kaisha (KK)

A KK is taxed at 2 levels. First, the KK is subject to corporate tax; then, shareholders are taxed on any dividends distributed by the KK.

Godo-Kaisha (GK)

A GK is taxed at 2 levels. First, the GK is subject to corporate tax; then, members are taxed on any dividends distributed by the GK.

Private limited liability company (Société à responsabilité limitée or S.à r.l.)

The company pays a corporate tax on its corporate income (currently at the rate of 24.94 percent), and a withholding tax may apply when dividends are paid to its shareholders (at the rate of 15 percent, subject to reduction under applicable tax treaties). Exemptions are available under certain conditions.

Public limited liability company (Société anonyme or S.A.)

The company pays a corporate tax on its corporate income (currently at the rate of 24.94 percent), and a withholding tax may apply when dividends are paid to its shareholders (at the rate of 15 percent, subject to reduction under applicable tax treaties). Exemptions are available under certain conditions.

Special limited partnership (Société en commandite spéciale or SCSp)

The SCSp is, in principle, tax transparent.

A private limited company pays a corporate tax on its profits. These profits may then be distributed to their shareholders as dividends.

Companies incorporated in Mauritius are liable to pay income tax at the uniform rate of 15 percent. However, a Global Business Corporation is entitled to foreign tax credits and may opt to claim credit for actual tax paid in another jurisdiction, resulting in an effective tax rate of 3 percent, or 0 percent in certain circumstances.

A Global Business Corporation that is controlled and managed and is tax resident in Mauritius may, upon written approval from the Commissioner of Income Tax, benefit from tax relief from any of the double taxation treaties Mauritius has with other countries.

An Authorized Company is not considered as resident for tax purposes and therefore cannot claim double taxation relief under the double taxation treaties in force in Mauritius.

There is no withholding tax in Mauritius on capital gains, dividends or interest, nor any stamp duty levied.

S.A. de C.V.

A S.A. de C.V. is taxed at 2 levels (commonly referred to as double taxation). First, the S.A. de C.V. pays a corporate tax on its corporate income; then, the S.A. de C.V. distributes profits to shareholders, who then pay income tax on those dividends.

S. de R.L. de C.V.

A S. de R.L. de C.V. is taxed at 2 levels (commonly referred to as double taxation). First, the S. de R.L. de C.V. pays a corporate tax on its corporate income; then, the S. de R.L. de C.V. distributes profits to partners, who then pay income tax on those dividends.

S.A.P.I. de C.V.

A S.A.P.I. de C.V. is taxed at 2 levels (commonly referred to as double taxation). First, the S.A.P.I. de C.V. pays a corporate tax on its corporate income; then, the S.A.P.I. de C.V. distributes profits to shareholders, who then pay income tax on those dividends.

Branch office

Entities that are not a resident of the Netherlands for tax purposes are subject to Dutch corporate income tax, only if and to the extent income is derived and gains are realized from specific Dutch sources. An important category of income that is subject to Dutch corporate income tax is tax profit derived from a business carried on in the Netherlands by a non-tax resident entity via a Dutch permanent establishment or a Dutch permanent representative.

B.V. (private company with limited liability)

Dutch corporate income tax is imposed on worldwide profits of the BV. The tax rate on the first EUR200,000 of taxable profit is 19 percent. The rate on taxable profit in excess of EUR200,000 is 25.8 percent. Benefits derived by the BV from a so-called participation (deelneming) in an entity are exempt from Dutch corporate income tax (participation exemption) (deelnemingsvrijstelling). The participation exemption seeks to prevent double taxation of business profits at different corporate levels.

Co-operative U.A.

Dutch corporate income tax is imposed on worldwide profits of the co-operative. The tax rate on the first EUR200,000 of taxable profit is 19 percent. The rate on taxable profit in excess of EUR200,000 is 25.8 percent. Benefits derived by the co-operative from a so-called participation (deelneming) in an entity are exempt from Dutch corporate income tax (participation exemption) (deelnemingsvrijstelling). The participation exemption seeks to prevent double taxation of business profits at different corporate levels.

C.V. (a limited partnership)

A CV can either be considered tax transparent or opaque from a Dutch tax perspective. Depending on the partnership agreement, the tax status of the CV is determined.

Limited liability company

Limited liability company are subject to tax on its taxable profits. Profits are usually distributed by way of dividend authorised by the directors. Limited liability companies can attach imputation credits to a dividend that allows New Zealand tax resident shareholders to benefit from the tax paid by a company. In some circumstances, if imputation credits are attached, then it is not necessary to withhold tax from dividends.

Goods and Services Tax (GST)

Limited liability companies will generally be required to register for GST.

Branch

Foreign companies are taxed on their taxable profits as a separate entity in New Zealand, which will include all income derived from New Zealand less attributable expenses.

Goods and Services Tax (GST)

Foreign companies carrying on business in New Zealand through a branch may also be required to register for GST.

The following taxes are of general application to all companies in Nigeria, whether private or public:

• Companies Income Tax (CIT): The CIT is mandated to be paid by companies in Nigeria based on the profits made by the company. It is charged at a graduated scale depending on the turnover of the company. Companies with turnovers of NGN100 million or more are charged at 30 percent, medium companies with turnovers of NGN25 million to NGN100 million are charged at 20 percent and companies with turnovers less than NGN25 million are not required to pay CIT.
  • Nonresident companies (NRCs) providing professional, consultancy, management and technical services to residents in Nigeria are subject to tax at 10 percent where such company has a significant economic presence in Nigeria, while the income of NRCs with permanent establishment in Nigeria is taxable based on actual profits as resident companies.
  • Withholding tax (WHT) is a tax payment method which ensures income tax collections from the payer of the income due to the recipient company. Generally, WHT is charged at the following rates:
    • Dividend, interest, and rents at 10 percent
    • Royalties at 10 percent
    • Hire of equipment, motor vehicles, plants and machinery at 10 percent
    • Commission, consultancy, technical and management fees, legal fees, audit fees and other professional fees at 10 percent
    • Construction of roads bridges, building and power plant or other types of construction at 5 percent
    • All types of contracts and agency arrangements, other than sales in the ordinary course of business, at 5 percent
• Captial Gains Tax (CGT): The CGT is a 10-percent charge on the profits or gains realized by a company upon the disposal of chargeable assets. Chargeable assets are:
  • Any foreign currency
  • Gains from share disposal of a Nigerian company’s shares where the proceeds from the disposal are more than NGN100 million
  • Compensation for loss of office where the payments exceed NGN10 million
  • Any form of property created by the person disposing of it or otherwise coming to be owned without being acquired
  • Options, debts and incorporeal property, generally
• Education Tax: This tax is imposed on Nigerian companies and has recently been increased from 2 percent to 2.5 percent of all assessable profit for each year of assessment and is payable within 2 months of an assessment notice from the Federal Inland Revenue Service (FIRS).
• Police Fund Levy: This is a levy under the Nigerian Police Trust Fund Act of 0.005 percent of the net profit of companies operating in Nigeria.
• Personal Income Tax: This is a tax that is levied on the income of individuals employed in a company.  It is charged at a graduated scale from 7 to 24 percent depending on the amount of the taxed individual.  However, every taxable person is liable to a minimum income tax of 1 percent of their gross income save those earning minimum wage or less. Stamp Duties: The Stamp Duties Act regulates the payment of stamp duties on instruments in Nigeria. For the purposes of stamp duty assessment, instrument is defined to include every written document. The Act requires that any instrument executed in Nigeria, or whosesoever executed, which relates to any property situate in Nigeria, or to any matter or thing done, or to be done in Nigeria, must be stamped upon payment of the requisite stamp duty at the rate specified in the Schedule to the An instrument which is not duly stamped will not, except in criminal proceedings, be admissible in evidence in a court of law in Nigeria or be available for any other purpose whatsoever. The duties payable under the Act are divided into fixed duties and ad valorem duties. Fixed duties do not vary with the consideration for the document to be stamped; ad valorem, on the other hand, vary with the amount of consideration and in accordance with the scales stated in the schedule of the Act.
• Value-Added Tax (VAT): All suppliers of goods and services (except exempt) are required charge a 7.5 percent tax on their invoices, collect the tax form buyers and remit the amount so collected to the relevant VAT authorities. The scope of goods has been expanded to include any intangible products, asset or property except interest in land. However, exemptions are granted in respect of all medical and pharmaceutical products, basic food items, books and educational items, baby products, fertilizer, agricultural and veterinary medicine, farming machinery and farming transport equipment.
• It should be noted that employers of labor are expected to make contributions to social security schemes such as the Employee Compensation Scheme at a minimum monthly contribution of 1 percent of their monthly payroll managed by the Nigeria Social Insurance Trust Fund. Similarly, the employer must contribute 1 percent of their annual payroll cost to the Industrial Training Fund, 2.5 percent of their monthly basic salary to National Housing Fund and 18 percent of monthly emoluments to their pension.

Private LLCs

Private LLCs are taxed at 2 levels. At first a private LLC pays a corporate tax on its corporate income; next a private LLC distributes profits to shareholders who then pay income tax on those dividends. Dividend received by legal entities being shareholders may be taxed at a lower level.

Public LLCs

Public LLCs are taxed at 2 levels. First, a public LLC pays a corporate tax on its corporate income; next a public LLC distributes profits to shareholders who then pay income tax on those dividends. Dividend received by legal entities being shareholders may be taxed at a lower level.

Partnerships with unlimited liability

Pass-through entity with only 1 level of taxation. The partnership profits "pass through" to the partners, who then pay taxes on the profits at their individual tax rates.

The Peruvian tax regime levies taxes at 2 levels. First, the company pays a corporate tax on its income. Then, stockholders pay a personal tax on dividends. The structure of the general tax regime is the following:

Distributed or partially integrated tax regime: Corporate tax is paid by the company at a 29.5 percent rate. To this regard, domiciled entities are subject to Peruvian Income Tax on a worldwide basis; however, branches, agencies, and permanent establishments of non-domiciled entities incorporated in Peru are subject to Peruvian Income Tax only on their Peruvian-sourced income. Peruvian income tax applies on an annual and accrual basis and taxpayers are also subject to monthly advanced income tax payment.

In addition, stockholders pay personal tax only on distribution by the company. To this regard, non-domiciled and domiciled individuals are subject to a withholding tax at a rate of 5%. Domiciled entities are not subject to withholding tax.

Other regimen: there are some other tax regimes applicable to corporations with an annual revenue up to -approximately- US$ 130,000 (Régimen Especial del Impuesto a la Renta - RER) and -approximately- US$ 1’856,079 (Regimen de la Micro y Pequeña Empresa – RMYPE).

Under RER, the income tax is determined applying a 1.5% on the monthly revenue and in the RMYPE the tax rate is applied on net income, as follows:

Net Income	Rate
Up to -approximately- US$ 15,000	10%
Excess	29.5%

Subsidiary

• Subject to corporate income tax for income from sources within and outside the Philippines.
• Also subject to value-added tax (VAT) for gross receipts derived from sale, barter or exchange of goods or properties/services rendered in the Philippines.
• Also subject to local business taxes.
• Dividends received by the foreign entity/head office from its subsidiary are subject to withholding tax without prejudice to applicable treaties and domestic law provision, allowing the dividends tax sparing rate of 15 percent subject to conditions.

Branch office

• Subject to income tax from sources within the Philippines

• Subject to VAT and local business taxes

  Subject to branch profit remittance tax

Representative office

Not subject to income tax, VAT or local business taxes as it is not allowed to earn income from the Philippines.

Regional or area headquarters

Not subject to corporate income tax or local business taxes, but subject to VAT.

Regional operating headquarters

Subject to income tax and VAT but not subject to local business taxes except real property taxes on land improvements and equipment.

Partnership

Subject to regular corporate income tax, VAT and local business taxes.

Corporations are subject to Polish taxes, including corporate income tax (19 percent), VAT on goods and services provided (different rates up to 23 percent) and personal income tax on dividends paid out (19 percent). Special conditions apply to branches and representative offices because they do not constitute separate legal entities under Polish law.

Partnerships (except limited partnerships and limited joint-stock partnerships) are exempt from corporate income tax – income tax is only paid by the partners.

Tax on Dividends: Dividends paid to a non-resident company are subject to a 25 percent withholding tax (35 percent if paid to a company incorporated in a tax haven or offshore jurisdiction). However, as per the Portuguese qualified shareholding exemption regime, dividends received from a domestic company may be exempted if certain criteria set out in the law are met and the recipient of the dividends is resident in EU/EEA or in a jurisdiction covered by a tax treaty. If the qualified shareholding exemption regime does not apply, the rate may be reduced under the provisions of a tax treaty.

Other Taxes: Other operations between a company and other non-resident companies may be subject to tax or other reporting tax obligations which must be assessed, on a case-by-case analysis (eg, transfer pricing).

Corporations

A corporation is taxed at 2 levels (commonly referred to as double taxation). First, the corporation pays a corporate tax on its corporate income; then, when the corporation distributes profits to its shareholders, they  pay income tax on those dividends.

Limited Liability Companies

LLCs are taxed by default as corporations and are subject to tax at both the business entity and member levels. However, an LLC may elect to be treated as partnership for tax purposes, receiving pass-through treatment by making an election on Form SC 6045, which must be filed on or before the due date, including extensions, of the LLC’s Puerto Rico income tax return for the taxable year in which the election is to become effective. The Secretary of the Puerto Rico Treasury Department may issue further guidance as to the form and manner of making such election. Although a Puerto Rico LLC is automatically treated as a corporation for US federal income tax purposes, it may elect to be treated as a partnership or disregarded entity, as applicable. This election is accomplished through the filing of Form 8832 with the IRS.

Similar tax and accounting reporting requirements are applicable for both JSCs and LLCs established in Romania. Further to the incorporation, both JSCs and LLCs are in principle subject to the following taxes:

• The micro-companies tax: JSCs and LLCs have the option to pay a micro-companies tax of 1 percent (subject to meeting specific criteria, including the obligation to have at least 1 employee and register a level of turnover below EUR0.5 million)s is higher than EUR1 million, JSCs and LLCs are subject to 16 percent profit tax, applied on the fiscal result determined starting from the accounting profits adjusted with fiscal items

• Profit tax: the default tax regime for local entities. Under this regime,  JSCs and LLCs are subject to 16 percent profit tax, applied on the fiscal result determined starting from the accounting profits adjusted with fiscal items (non-taxable income and/or non-deductible expenses, as the case may be).

• Value added tax (VAT): the standard VAT rate in Romania is currently 19 percent. The reduced VAT rates are of 9 percent (eg, for medicines, food and beverages - except alcohol, among others) or 5 percent (eg, for school manuals, books, newspapers and magazines, hotel accommodation and similar accommodation, restaurant and catering services, supplies of social housing including related land, in certain conditions). Registration for VAT purposes is required if the turnover resulting from the economic activity exceeds the threshold of RON300,000 in a calendar year

• Local tax: due by companies for assets in their patrimony (ie, for buildings, land and vehicles owned) or taxes on publicity and advertising and outdoor advertising
• Withholding tax (WHT): WHT is due on cross-border payment of dividends, interest, royalties, commissions and services. As per the domestic tax legislation, income derived by non-residents from Romania is, as a general rule, subject to 16-percent WHT in Romania. However, such rates can be reduced (even to nil) under the provisions of the EU Directives or double tax treaties entered into by Romania with different countries

• Salary and mandatory social security charges: the existence of employees at the level of the JSC and LLC triggers the obligation to pay salary tax and mandatory social security contributions. A flat income tax rate of 10 percent applies to the income obtained by employees. Moreover, both the employer and the employee are required to contribute to the social security system (ie, 35 percent cumulated contribution to pension and health funds due by employees working in normal conditions and labor insurance contribution of 2.25 percent due by the employer)

• Customs duties: applicable if JSC or LLC performs imports of goods from outside the EU to Romania (certain exemptions may apply though)
• Accounting requirements: both JSCs and LLCs are required to organize and manage its own accounts based on the Romanian accounting rules

Joint-stock company (public and non-public)

A company is taxed at 2 levels. First, the company pays profits tax on its corporate income; then, the company distributes dividends to shareholders and withholds the income tax on those dividends (where paid in cash), acting as a tax agent. Certain tax exemptions are available.

Limited liability company

A company is taxed at 2 levels. First, the company pays profits tax on its corporate income; then, the company distributes profits to members and withholds the income tax on those profits (where paid in cash), acting as a tax agent. Certain tax exemptions are available.

Limited liability company

A 15- percent value-added tax (VAT) is currently applied on most goods and services. Depending on the circumstances, corporate income tax, zakat, capital gains tax and withholding tax may also be applicable.

Limited liability company

A company is resident for Singapore tax purposes if it is managed and controlled in Singapore. In practice, the Inland Revenue Authority of Singapore (IRAS) considers a company managed and controlled in Singapore if the board of directors meetings where strategic decisions are made are held in Singapore.

Private companies and public companies

A company incorporated in South Africa (SA) or which has its place of effective management in SA will be treated as a tax resident, subject to an applicable treaty.

Private and public companies must register as taxpayers with the South African Revenue Service (SARS).

From April 1, 2023, all South African resident companies are expected to pay Corporate Income Tax (CIT) on the income generated worldwide at a rate of 27 percent. An SA corporate resident is generally not subject to SA tax on the income of its  foreign subsidiaries until it is repatriated, unless the Controlled Foreign Company (CFC) rules apply.

Non-resident companies are generally not subject to SA tax except on:

• Their income which is sourced in SA
• Income derived from a trade carried on through a permanent establishment in SA
• Capital gains from the disposal of:
  • SA assets attributable to a permanent establishment in SA; or
  • Immovable property or an interest in immovable property situated in SA.

Tax treaties can reduce or eliminate taxes payable by non-residents.

Tax compliance

Resident and foreign companies are generally required to submit income tax returns within 12 months from the date on which the relevant financial year ends.

All companies (including foreign companies with a South African branch) are required to make provisional tax payments in respect to their SA tax liability. Provisional tax payments are advance tax payments in respect of income tax payable for the tax year and reflect as a credit against the income tax finally assessed.

Tax rulings

Taxpayers can approach SARS for advance tax rulings. However, SARS will not give an advanced ruling on certain issues (e.g., transfer pricing, general anti-avoidance, matters of a factual nature, etc.).

Distributions

Distributions paid by a company are generally treated as a dividend to shareholders, unless the board of a corporate entity determines that the distribution results in a reduction of contributed tax capital. A return in capital in excess of a shareholder's tax base will normally be treated as a capital gain.

Generally, dividend distributions by SA resident companies are exempt from income tax. In certain instances, SA companies can rely on participation exemptions for dividends received from or capital gains realized on the shares in foreign companies.

Dividend, royalties, interest and foreign entertainment withholding taxes apply.

A 20% withholding tax applies to dividends whereas the other withholding taxes are imposed at a rate of 15%. Withholding taxes may be reduced in terms of tax treaties.

Capital Gain

Capital gains tax (CGT) applies to a resident's worldwide assets and in the case of a non-resident, to their immovable property, shares in a land rich company or assets of a permanent establishment in SA.

CGT is triggered on the disposal or deemed disposal of an asset and is calculated as being the difference between the proceeds and the base cost of the asset. Assessed capital losses are carried-forward and may be set-off against capital gains in the following year of assessment. Provision is made for exclusions and rebates, as well as rollover relief, where the gain made from a disposal is disregarded until ultimate disposal of the assets. The effective capital gains tax rate for corporates is 21.6%.

Transfer Taxes

The transfer of securities of a private or public company incorporated in SA is subject to securities transfer tax (STT) at a rate of 0.25 percent.

STT is charged on the greater of the market value of the security or the amount of consideration given. Provision is made for exclusions in the case of certain inter-company transfers, lending arrangement and transfers between non-taxable organisations.

Employment Taxes

Employers are required to deduct employees tax (PAYE) on all remuneration paid to employees, including directors, unless a tax deduction directive is issued by SARS. Fringe benefits are included in remuneration.

Employers may also be required to deduct and pay unemployment fund contributions and skills development levies.

Value Added Tax

South Africa imposes Value-Added Tax (VAT) at the standard rate of 15 percent on the supply of goods or services on a destination basis, i.e. VAT is borne by the final consumer of goods or services. The primary mechanism to ensure that only local consumption is taxed in South Africa is through the zero rating (0 percent) of certain goods and services exported and the levying of VAT on the importation of goods and certain services.

It is mandatory for any business to register for VAT with SARS if its taxable supplies in any twelve month period exceeds R1 million or when it has a contractual obligation in writing to make supplies of R1 million in a 12 month period. A business may also choose to voluntarily register for VAT if the value of taxable supplies made or to be made is less than R1 million, but has exceeded R50 000 in the past 12 months.

Subject to certain exclusions in the recently revised regulations on electronic services for VAT purposes issued by the South African National Treasury, the provision of electronic services (as defined in the South African Value-Added Tax Act 89 of 1991)  by foreign entities to South African customers (including businesses) is generally subject to VAT in South Africa and at least two of the following circumstances are present:

• The customer is a South African resident;
• The payment of the services originates from a South African bank account; or
• The customer has a business, residential or postal address in South Africa.

External companies

If an external company retains its effective management offshore, it will be considered a non-resident and therefore will only be charged CIT on South African sourced income.

Dividends’ tax is not imposed on any profits remitted offshore. The same VAT requirements for private and public companies apply to an external company.

Joint-stock company (Jusik Hoesa)

A joint-stock company pays corporate tax on its corporate income and distributes profits to shareholders who then pay income tax on those dividends.

Limited company (Yuhan Hoesa)

A limited company pays corporate tax on its corporate income and distributes profits to members who then pay income tax on those dividends.

Branch (Sucursal)

Branches are taxed on the profits allocated to the permanent establishment.

Limited liability company (Sociedad Limitada)

Taxed on its earnings at a corporate level and shareholders are taxed on any distributed dividends, although double taxation relief may apply.

Joint-stock company (Sociedad Anónima)

Taxed on its earnings at a corporate level and shareholders are taxed on any distributed dividends, although double taxation relief may apply.

Limited company (aktiebolag, AB)

Profits of an AB are taxed at 2 levels (commonly referred to as double taxation). First, an AB pays a corporate tax on its corporate income; then, shareholders pay tax on profits distributed from an AB. An AB is subject to a Swedish corporate income tax rate which currently amounts to 20.6 percent.

Trading partnership (handelsbolag, HB)

Partners are taxed based on their part of the HB's surplus which includes income tax and social security contribution.

Limited partnership (kommanditbolag, KB)

Partners are taxed based on their part of the KB's surplus which includes income tax and social security contribution.

Branch office (filial, Branch)

A foreign company starting a branch in Sweden must pay income tax on its business operations. Branch accounts must be kept separate from those of a foreign company in order to calculate the accrued profit. Profit of a branch is then subject to Swedish corporate income tax rate which currently amounts to 20.6 percent.

Stock corporation

A stock corporation is taxed at 2 levels (so-called economic double taxation). First, the stock corporation pays a corporate tax on its corporate income; when the stock corporation distributes profits to shareholders, they pay income tax on those dividends. Capital tax is only levied on a cantonal and communal level.

Company limited by shares

A company (including an FIA company) is taxed on its worldwide net income.

Closely-held company limited by shares

A CHC (including an FIA company) is taxed on its worldwide net income.

Limited company

A company (including an FIA company) is taxed on its worldwide net income.

Branch office of a foreign company

A branch office is taxed on its own (exclusive of its foreign head office’s) net income.

Private limited company

A private limited company is subject to corporate income tax. The shareholders are subject to income tax on the dividends paid to them.

Public limited company

A public limited company is subject to corporate income tax. The shareholders are subject to income tax on the dividends paid to them.

Partnerships

Unregistered ordinary partnership

Partners of an unregistered ordinary partnership must pay personal income tax at a progressive rate.

Registered ordinary partnership

A registered ordinary partnership is subject to corporate income tax. The partners are subject to income tax on the profit distributions from the registered ordinary partnership.

Limited partnership

A limited partnership is subject to corporate income tax. The partners are subject to income tax on the profit distributions from the registered limited partnership.

Joint-stock company (JSC)

A JSC's profit is subject to 20 percent corporation income tax for 2023.

Limited liability company (LLC)

An LLC's profit is subject to 20 percent corporation income tax for 2023.

Limited liability company (LLC)

Company's profits are taxed at 2 levels: corporate profit tax is applied directly on the company's profits, and income tax is imposed on dividends distributed to participants.

Private Joint-Stock Company

Company's profits taxed at 2 levels: corporate profit tax is applied directly on the company's profits, and income tax is imposed on any dividends distributed to shareholders.

LLC

The UAE has long been known as a zero-corporate-tax jurisdiction. This is set to change with the Ministry of Finance’s (MOF) announcement on January 31, 2022 that the UAE will introduce a federal corporate income tax (CIT) effective for financial years starting on or after June 1, 2023. Because the UAE is an Inclusive Framework member of the Organisation for Economic Cooperation and Development’s (OECD) anti-Base Erosion and Profit Shifting initiatives, it has been expected that it would introduce legislation to implement the multinational-focused Global Minimum Corporate Tax (GMCT) of 15 percent. With MOF’s recent announcement, more details have been revealed on the contours of the UAE’s CIT regime.

While the formal CIT legislation has not yet been published, MOF’s announcement states that CIT will be payable on the profits of UAE businesses as reported in their financial statements prepared in accordance with internationally acceptable accounting standards. CIT will apply to all businesses and commercial activities alike, except for the extraction of natural resources, which will remain subject to Emirate-level corporate taxation.

The standard statutory CIT rate will be 9 percent, whereas a 0-percent rate will apply for taxable profits up to AED375,000 to support small businesses and startups. Multinationals earning more than EUR750 million in global revenues will be subject to a 15-percent CIT rate, which constitutes the UAE’s implementation of the GMCT.

No personal income tax or corporate taxes payable, save for companies engaged in oil, gas, hospitality and petrochemical activities, among others. There are some municipality taxes on rent and certain land transfer charges paid  when transferring real estate. Effective January 1, 2018, the UAE has implemented a value-added tax (VAT) at a rate of 5 percent, as recommended by the World Bank and the International Monetary Fund.

Branch

Same as LLC.

FZ-LLC

No personal income tax or corporate taxes payable. The UAE contains many free zones in the UAE, where international groups have been exempt from payment of VAT, but, in all other non-designated free zones, VAT is applicable to establish 100-percent owned subsidiaries. Most free zones provide tax incentives to companies and branches established therein, which are typically valid for a number of years.  According to the MOF, free zone businesses will be subject to the new CIT; however, the CIT regime will continue to honor the tax incentives offered to free zone businesses that comply with all regulatory requirements and that do not conduct business with mainland UAE (ie, with parties outside of the Free Zone). The designated free zones which are exempt from VAT are set out below:

Abu Dhabi

1. Abu Dhabi Global Market
2. Twofour54
3. Masdar City Free Zone
4. Free Trade Zone of Khalifa Port
5. Abu Dhabi Airport Free Zone
6. Khalifa Industrial Zone

Dubai

1. Dubai International Financial Centre
2. Dubai Development Authority
3. Dubai Multi Commodities Centre
4. Dubai Healthcare City
5. Dubai Silicon Oasis
6. Dubai World Trade Centre
7. Jebel Ali Free Zone (North-South)
8. Dubai Cars and Automotive Zone (DUCAMZ)
9. Dubai Textile City
10. Free Zone Area in Al Quoz
11. Free Zone Area in Al Qusais
12. Dubai Aviation City
13. Dubai Airport Free Zone

Sharjah

1. Hamriyah Free Zone
2. Sharjah Airport International Free Zone

Ajman

1. Ajman Free Zone

Umm Al Quwain

1. Umm Al Quwain Free Trade Zone in Ahmed Bin Rashid Port
2. Umm Al Quwain Free Trade Zone on Sheikh Mohammed Bin Zayed Road

Ras Al Khaimah

1. RAK Economic Zone (RAKEZ)
2. RAK Maritime City Free Zone
3. RAK Airport Free Zone

Fujairah

1. Fujairah Free Zone
2. Fujairah Oil Industry Zone (FOIZ)

FZ-Branch

Same as FZ-LLC.

Dual Licence Branch

Same as Branch.

Private limited company

Company's profits taxed at 2 levels: Corporation tax is applied directly on the company's profits. In addition, income tax is imposed on any dividends distributed to shareholders. Company may be under a duty to withhold tax (eg, when paying interest).

Limited liability partnership (LLP)

Generally taxed as a partnership. Individual members liable for income and capital gains tax on their share of LLP's profits/gains.

Registered UK establishment

An overseas company is subject to corporation tax on its profits only to the extent that those profits are attributable to the UK establishment.

C corporation

A C corporation is taxed on its income at 2 levels (commonly referred to as double taxation). First the C corporation pays income taxes on its corporate income; then if C corporation distributes profits to shareholders, such shareholders then pay income tax on those dividends. Many C corporations are set up where the shareholders do not intend to distribute profits by dividends.  If a C corporation is part of a consolidated tax group where the C corporation is not viewed as a separate taxable entity, the double taxation effect is mitigated.

S corporation

Pass-through entity taxed like a partnership, as there is only 1 level of income taxation. The corporate profits “pass through” to the owners, who pay income taxes on the profits at their individual tax rates.

Limited liability company (LLC)

Unless the LLC elects to be treated as a corporation, it is a pass-through entity taxed like a partnership, as there is only one level of income taxation. The corporate profits “pass through” to the owners, who pay income taxes on the profits at their individual tax rates.

Joint stock company (JSC)

The JSC is liable to pay corporate income tax levied on its earnings, and shareholders (only individuals) are taxed on any distributed dividends.

Limited liability company with two or more members (LLC2)

The LLC2 is liable to pay corporate income tax levied on its earnings, and members (only individuals) are taxed on any distributed profits.

Limited liability company with one member (LLC1)

The LLC1 is liable to pay corporate income tax imposed on its earnings. However, the sole member (either a legal entity or an individual) is not taxed on its distributed profits.