Austria 25% of the annual profits; annual minimum corporate tax in the amount of EUR 1,750.
The minimum corporate tax is reduced for a newly founded LLC and amounts in the first five years EUR 500 and the following five years EUR 1,000.

Brazil Corporate Income Tax (“IRPJ”): 15% plus a surcharge of 10% on taxable profits exceeding BRL 240,000.00 per year.
Social Contribution on Profits (“CSLL”): 9%.
Combined rates for corporate taxes: 34%.

China Generally corporate income tax (CIT) rate is 25%. Preferential tax treatment may be granted to a foreign-invested enterprise (e.g. in certain regions or if you qualify as a so-called "high-tech enterprise").

Czech Republic The basic corporate tax rate is 19%; however, due to the recent government’s consolidation package, as of 1 January 2024, the rate is expected to be increased to 21%. Investment funds have a special tax rate of 5% and for pension funds the rate is 0% with some exceptions upon termination.

Self-employed persons (sole-traders) with a yearly income not exceeding CZK 2,000,000 (approx. EUR 82,000) may opt to pay a fixed monthly tax including health insurance and social security payments. The fixed monthly tax depends on the threshold (3 thresholds) of income and ranges from CZK 7,498 (approx. EUR 307) to CZK 27,139 (approx. EUR 1,110).

England & Wales For the financial year 2024/2025 the main rate of corporation tax is 25% for profits over £250,000. A small profits rate of 19% applies to profits of £50,000 or less. Businesses with profits between £50,000 and £250,000 will be taxed at the main rate but may claim marginal relief.

France For financial years beginning on or after January 1, 2022, the standard CIT rate is set at 25% for all companies, regardless of their turnover.

Under certain conditions, SMEs with an amount of turnover not exceeding EUR 10 M can benefit from a CIT rate of 15% on their first EUR 38.120 of taxable profits (EUR 42.500 for taxation of results for financial years ending on or after December 31, 2022).

Germany Corporate income tax rate: 15.825% including solidarity surcharge plus trade tax rate: approx. 13% - 18%. Trade tax rate depends on the municipal assessment rate.

Hong Kong 8.25% on assessable profits up to HK$2,000,000; and 16.5% on any part of assessable profits over HK$2,000,000 (only for profits arising in or derived from Hong Kong).

Hungary The corporate tax rate at a national level is 9%. The corporate tax is calculated by multiplying the positive tax base by the tax rate. At local level there is usually a turnover based tax amounting to maximum 2%.

Ireland Current rate (For the tax year 2023) 12.5% (trading profits)

25% (passive income).

Italy 24% (corporation tax) + 3,9% (regional tax)

Netherlands Corporate taxpayers are subject to corporate income tax on their worldwide income. In 2024 the rate is 19% over the first EUR 200,000 and 25,8% over the surplus.

A reduced rate applies to activities covered by the innovation box. The tax rate for qualifying income allocable to the innovation box is 9% in 2024. The innovation box provides tax relief to encourage innovative research. Qualifying profits earned from innovative activities are taxed at this special rate if specific conditions are met.

Poland The standard CIT rate is 19% on annual profit, however a reduced tax rate of 9% is available to a company that:

(i) does not earn more than EUR 2 m (its equivalent in PLN) of income (revenue) in a current fiscal year, and

(ii) did not earn more than EUR 2 m (its equivalent in PLN) of income (revenue) from sales, including output VAT if applicable, in the preceding fiscal year.

Portugal Taxable result is taxed at the general rate of 21% (reduced tax rate of 17% applies to the first € 50,000 of taxable profits assessed by small and medium-sized enterprises). Companies’ resident in Madeira or Azores are taxed at the general rate of 14.7% (reduced tax rate of 11.9% applies to the first € 50,000 of taxable profits assessed by small and medium-sized enterprises). A Municipal Surcharge up to 1.5% may be added over the taxable profit. Also, a state surcharge up to 9% may be added on the part of taxable profits over € 1,500,000.

Singapore 17%

Slovakia The company (corporate) income tax rate for Slovakia is determined by the revenue (income) of the company. Companies with annual revenue (income) not exceeding the threshold of EUR 49.790,- will be subject to a reduced tax rate of 15 %. Companies exceeding the said threshold will be subject to a 21 % corporate income tax rate.

New regulation introduces a definition of "micro-taxpayer" applicable to businesses (natural persons or legal entities) with annual revenue (income) not exceeding EUR 49.790,- (ie the amount of the turnover mandatory for the VAT registration). Various beneficial tax conditions apply to this group of taxpayers, such as more beneficial conditions of tax loss deduction, or simplified depreciation rules.

Spain Current rate: 25% (for entities whose net turnover
for the immediately preceding tax period is less
than 1 million euros is 23%).
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Newly incorporated entities may apply a reduced
Corporate Income Tax rate of 15% applicable in
the first two years in which they generate positive
taxable income.

United Arab Emirates There is currently no corporate tax for legal entities generally. However, the UAE has announced the introduction of federal corporate tax (“CT”) on the net profits of certain businesses (with limited exemptions applying). CT will be applicable on financial years starting on or after 1 July 2023 with a standard rate of 9%, and a 0% tax rate for taxable profits up to AED 375,000 to support small businesses and startups. .

A few exceptions related to specific industries such as finance and oil and gas exist.

Austria General VAT rates (may temporarily be reduced due to COVID-19-legislation): 20%, 13%, 10%, 0%.

General obligation to pay VAT if turnover is realised.

Pre-tax deduction (Vorsteuerabzug) is possible under certain circumstances.

Brazil Brazilian tax system does not have a single tax as the VAT. Instead, it divides the taxes into:
(i) ISS (Tax on Services): a local tax whose rate ranges from 2% to 5% depending on the municipality;
(ii) ICMS (Tax on sales, transport and telecommunication tax): a state tax whose rate ranges up to 25% depending on the state:
- sale and circulation of goods: generally, 7% or 12% depending on the state;
- transactions within the same state: 17%, 18% or 20%;
- telecommunication and electricity: generally, 25%.
(iii) PIS/COFINS (Federal VAT): due on gross revenues, whose combined rate is 9.25%.

China China implements a VAT system applicable to both sales of goods and provision of (most) services. Usual VAT rates are 6%, 9% and 13%. Input VAT credit: General VAT-payers are allowed to offset input VAT incurred on the purchase of goods / services against payable output VAT.

Czech Republic 21% - standard rate
15% - first reduced rate (food, non-alcoholic beverages, restaurant and hotel services etc)
10% - second reduced rate (essential child nutrition, gluten-free food, some pharmaceutical products, newspapers and periodicals)

Due to the recent government’s consolidation package, as of 1 January 2024, the first reduced rate and second reduced rate are expected to be merged into a single reduced rate 12% and new 0% rate will be set for books.

England & Wales 2024/2025:
Standard rate: 20%

Reduced rate: 5%

Zero rate: 0%

Most goods and services are standard rated.

The ‘transfer of a business as a going concern’ (TOGC) is outside the scope of VAT, if certain conditions are met.
Share purchases are generally VAT exempt.

France 20% - Standard rate

Germany General VAT rate: 19%
Reduced VAT rate: 7% (eg. on print media)

Hong Kong None.

Hungary 27% - Standard rate

Ireland Standard rate for the tax year 2022 (23%)

Reduced rates for the tax year 2022: 0% (Zero Rate), 4.8% (Livestock Rate), 5.5% (Flat-rate Compensation Percentage for Farmers), 9% (Second Reduced Rate) and 13.5% (Reduced Rate).

Most goods and services are standard rated.

The 'transfer of a business' (TOB) is outside the scope of VAT, if certain conditions are met.

Share purchases are generally exempt.

Italy 22% (standard rate)

Netherlands The standard VAT rate is 21%.

A lower rate of 9% may apply to specific products and services (such as food products, medicines, and books).

A 0% rate in principle applies for supply of goods and services from the Netherlands to business customers in another EU Member State .

For supply of goods from the Netherlands to customers outside the EU, also a 0% export rate is applicable. Services to customers outside the EU are in principle outside the scope of Dutch VAT.

Furthermore, specific services and goods that are provided in the Netherlands can fall under the 0% rate or a VAT exemption.

Poland The standard VAT rate is 23%. This rate applies to almost all supplies of goods and services, unless specific VAT regulations provide reduced rates – 8%, 5% or 0%.

Under some conditions the supply of goods or services can be exempt from VAT.

Portugal VAT is levied on the supplies of goods and services, import of goods and intracommunity acquisition of goods. The tax is primarily borne by the consumers, though it should be delivered to the State by the Taxable persons, which are, as a rule and under certain conditions, allowed to deduct the VAT borne on supplies of goods and services in connection with their taxable activities.

Singapore 9% (from 1 January 2024)

Slovakia The standard VAT (sales tax) rate in Slovakia stands at 20% with a reduced VAT rate of 10% applicable to certain goods, eg certain groceries, medical products etc; as of 1 January 2020, the said list of goods was extended to newspapers, magazines, articles and several types of healthy food. Certain supplies (universal postal services, insurance services, financial services) are exempt from tax.

Spain Standard rate: 21%
Reduced rate: 10% and 4%
Most goods and services are standard rated.
The 'transfer of a business as a going concern' is outside the scope of VAT, if certain conditions are met. Share purchases are generally VAT exempt.

United Arab Emirates Value Added Tax was implemented in the UAE on 1 January 2018, pursuant to Federal Decree Law No. 8 of 2017 (the 'Tax Law').

The Tax Law requires that any taxable person (individual or corporation) who is providing goods or services in the UAE with a value in excess of the mandatory threshold (AED 375,000) to register for, charge for and pay VAT to the Federal Tax Authority (FTA).


VAT will apply on the supply of goods and services in the UAE (including imports) except on the exempt goods and services as specified under the VAT Law. The standard rate of VAT is currently set at 5% on any supply or import of goods or services.


There are a number of goods and services which are zero rated (including exports outside the GCC, newly constructed residential properties, education services and healthcare services), for which VAT will be charged at 0%, and others which are exempt entirely (including financial services).


The place of supply determines whether a supply is made in the UAE or outside the UAE. As such, if the supply is treated as made outside the UAE, VAT is not chargeable. However, if a supply is made in the UAE, VAT may be chargeable. In relation to goods, the place of supply is the location of the goods when the supply occurs and VAT is chargeable for domestic supplies and exports. In relation to services, the place of supply is where the supplier has the place of residence.


For business-to-business imports into the UAE from outside the UAE, the recipient accounts for VAT under a 'reverse charge' mechanism.

Austria Depending on assessment basis (gross salary).

Brazil The Social Security Contribution is paid by the employer and by the employee. The calculation basis is the monthly payroll. The rates are:
(i) Employers: 28% (on average);
(ii) Employees: from 8% and 11% limited to a cap which is established every year.

China Statutory social security insurance consists of basic pension, basic medical, maternity, work injury, and unemployment insurances. There are plans to integrate maternity insurance into the basic medical insurance. On top of the social security insurance, there is also a housing fund program to be respected.

Contributions are made by the employer and partially also by the employee on a monthly basis. The exact contribution rates are set by the local governments within the overall statutory framework.

Foreign employees working in China are also generally required to participate in the Chinese social security insurance system, though this is not always strictly enforced throughout China. Exemptions may further apply under bilateral social insurance treaties.

Czech Republic Paid by employer – 24.8 %
Paid by employee – 6.5 % (7,1% as of 1 January 2024 due to the recent government’s consolidation package)
Self-employed – 29.2 %

England & Wales Tax year 2024/2025:

Employees' NICs: 8% for earnings between £242 and £967 per week and 2% on any excess.

Employers' NICs: 13.8% on any salary over £175 per week and on any taxable benefits (rising to 15% on any salary over £96 per week and on any taxable benefits from 6 April 2025).

France Between 40 and 45% for employers. Between 20 and 25% for employees.

Germany Social security contributions are payable only up to a set income level. The contribution ceilings are:


- Health and nursing insurance for all Federal States: EUR 4,837.50 (monthly) EUR 58,050 (yearly)


- Statutory remuneration ceiling: EUR 5,362.50 (monthly) EUR 64,350 (yearly)


- Special yearly statutory remuneration ceiling: EUR 58,050


- Pension and unemployment insurance:


- Old Federal States EUR 7,050 (monthly) EUR 85,200 (yearly)


- New Federal States: EUR 6,750 (monthly) EUR 80,400 (yearly)


Social security contributions are payable only up to a set income level. The contribution ceilings are described in the table below:


- Pension insurance: 18.6% (9.3% employer / 9.3% employee), up to an annual income ceiling of EUR 84,600 (Old Federal States) / EUR 81,000 (New Federal States)


- Unemployment insurance: 2.4% (1.2% employer / 1.2% employee), up to an annual income ceiling of EUR 84,600 (Old Federal States) / EUR 81,000 (New Federal States)


- Health insurance: 14,6% (7.3% employer / 7.3% employee), up to an annual income ceiling of EUR 64,350


- Nursing insurance: 3.05% (3,4% for childless employees, beginning with age 23), up to an annual income ceiling of EUR 64,350 (1.525% employer / 1.525% employee and 1.875% for childless employees, beginning with age 23; difference in Federal State Saxony)
-Insolvency contribution: 0.09% (only payable by employer), up to an annual income ceiling of EUR 85,200 (Old Federal States) / EUR 80,400 (New Federal States)

Hong Kong None.

Hungary The rates for 2023 are the following:


Employer: social tax amounting to 13 % of the tax base. The upper limit of the tax base is 24 times the mandatory minimum wage.


Employee: 18.5% social security contribution (consists of 10% pension contribution + 7% health insurance +1,5% labour market contribution).


Some local taxes can be payable by the owner of a building or land parcel depending on the local governments.

Ireland For the tax year 2023: 4% flat rate for employees, or nil for employees earning between €38 - €352 inclusive per week.

For the tax year 2023 generally 11.05% for employers, or the lower rate of 8.8% between €38 - €410 inclusive per week.

Italy Between 35% and 40% for employers. Between 20% and 25% for employees.

Netherlands National social insurance contributions integrated in income tax/wage tax/ Employees’ insurance contributions levied from employers and vary per industry.

Poland Payable both by the employee (13.71%) and employer (20.48% on top of the gross remuneration).

Portugal The standard contribution rate for Social Security is 34.75% (23.75% borne by the employer and 11% borne by the employee), regarding employment contracts.

Singapore Known as the Central Provident Fund (CPF) scheme. Generally, employer contribution rates from 1 January 2016 for private and public sector non-pensionable employees depends on their age.

Slovakia The social security system consists of social security and health insurance contributions. If an individual is on the Slovak payroll, the employer withholds social security on a monthly basis. A self-employed individual must also pay the social security and health insurance contributions related to their 'earnings'.


Health insurance contributions represent in 2022:


Self-employed: 14%


Employer and employee: employer: 10% and employee: 4%.


Social security contributions represent in 2022:


Self-employed: 33.15%


Employer and employee: employer: 25.20% and employee: 9.4%.

Spain The maximum monthly social security contribution base for year 2022 is €4,139.40. The rates applied to such base are as follows:

• Employees: maximum 6.3%.
• Employers: maximum 31.1% plus a variable rate depending on the activity.

United Arab Emirates In respect of social security, for UAE national employees social security contributions are calculated at a rate of 20% of the employee's gross remuneration (5% is payable by the employee, 12.5% is payable by the employer, and an additional 2.5% contribution is made by the Government) – for non-UAE nationals, there is no social security contributions.

Austria 27.5% on capital gains; however, this depends on group structure and applicable double taxation treaties.

Brazil Capital gains of residents and non-residents are taxed in progressive rates, as follows:
(i) 15% on gains that do not exceed 5,000,000.00 BRL;
(ii) 17.5% on gains that exceed 5,000,000.00 BRL and do not exceed 10,000,000.00 BRL;
(iii) 22% on the gains that exceed 10,000,000.00 BRL and does not exceed 30,000,000.00 BRL;
(iv) 22.5% on gains that exceed 30,000,000.00 BRL.

China Generally none; however foreign shareholders selling their equity interest in a Chinese subsidiary are subject to a withholding tax of 10% on capital gains.

Czech Republic For tax residents, gains derived from the sale of assets generally are included with other taxable income and taxed at the regular 15% personal income tax rate, respectively, 19% corporate income tax rate. Dividends and interest are subject to a 15% withholding tax at source.

Due to the recent government’s consolidation package, as of 1 January 2024, there could be variations to the above depending on individual cases.

England & Wales Tax year 2024/2025: for individuals to the extent taxable gains, when aggregated with taxable income, exceed £37,700 threshold:

For gains on carried interest: 28% (rising to 32% from 6 April 2025).

For gains on residential property not eligible for Private Residence Relief: 24%.

For other gains: 20% (from 6 April 2024 to 29 October 2024); 24% (from 30 October 2024).

Gains up to £3,000 (for tax year 2024/2025) are exempt.

Business Asset Disposal Relief (formerly known as Entrepreneurs' Relief) – individuals may qualify for a tax rate of 10% (rising to 14% from 6 April 2025 and to 18% from 6 April 2026) on certain disposals.

Chargeable gains made by companies (ie on the disposal of a business asset) are charged to corporation tax.

France For individuals: For capital gains on shares, individuals are in principle subject to (i) personal income tax at a 12.8% flat rate tax and (ii) social contributions at a 17.2% rate (i.e, an overall tax rate of 30%). Taxpayers may also elect for a taxation at the progressive income tax rates if more beneficial. If any, capital gains on shares will be subject to (i) personal income tax at the progressive scale up to 45%, after application of a tax allowance for length of ownership provided that the shares were acquired or subscribed before January 1, 2018, and (ii) social contributions at a 17.2% rate. This election is global for all equity revenue of a year (i.e., dividend, interest and capital gain). For real estate capital gains, individuals are in principle subject to (i) personal income tax at the rate of 19% after application of a tax allowance for length of ownership of the property (up to 100% after 22 years) and (ii) social contributions at the rate of 17.2% after application of a tax allowance for length of ownership (up to 100% after 30 years of ownership). An additional tax may be applied for real estate net capital gains exceeding 50k (up to 6%).

For companies: For capital gains on shares, an effective tax rate of 3% (i.e., capital gain subject to French standard CIT rate (25%) after an allowance of 88%) for substantial ownership (ownership of more than 5% of the company's share capital for more than two years).

Long-term capital gains arising on the sale of listed shares held for at least two years in real-estate companies are subject to a CIT rate of 19%.

Germany Private assets (individuals): 26.375% (incl. solidarity surcharge plus church tax, if any); Business assets (individuals): approx. 30% (incl. solidarity surcharge and church tax, if any); Business assets (corporations): approx. 1.5% (including solidarity surcharge).

Hong Kong None.

Hungary Two varieties of tax obligation apply:

- social tax amounting to 13% only up to a limit (in 2024) of HUF 832,416/year (approx. EUR 2,190).

- personal income tax amounting to 15%.

Ireland Tax year 2022: there is a standard rate of 33%.

Every Irish tax-resident individual has the benefit of an annual exemption that can be set against chargeable gains in a tax year (currently €1,270 for the tax year 2022).

Entrepreneurs' Relief (ER) - individuals may qualify for a tax rate of 10% on certain disposals.

Chargeable gains made by companies (i.e. on the disposal of a business asset) are charged to corporation tax.

Italy Individuals:
The substitute tax rate applied on the capital gains deriving from the sale of qualified or non-qualified participations stands at 26%.

Companies:
Capital gains on the transfer of shareholdings, under certain conditions, are 95% exempt from taxation. The legal conditions for exemption are the following:

i. uninterrupted holding from the first day of the 12th month preceding that of the transfer; holdings acquired more recently will be deemed to be transferred first (LIFO basis)

ii. classification of holdings as fixed asset investments from the first balance sheet closed during the period of ownership


iii. tax residence of the subsidiary in a country or territory other than those with a preferential tax system

iv. carrying out of actual commercial activities by the subsidiary.

Netherlands 0% to 25, 8%

Capital gains are included in taxable profits and subject to the normal corporate income tax rate. The basis for calculating a capital gain or loss is the difference between the book value of an asset and the amount for which the asset is sold (or fair market value).

However, under the participation exemption, realized capital gains (and dividends) derived from a qualifying shareholding in a subsidiary are exempt from corporate income tax.

If the participation exemption applies potential capital losses would not be tax deductible, except in the event such subsidiary would be liquidated (but only if certain stringent conditions are met).

Poland Capital gains are in general subject to 19% CIT or PIT rate, unless applicable tax treaty or Polish law provides otherwise.

Portugal Realized capital gains contribute for the company’s relevant year taxable income assessment and are taxed according with Corporate Income Tax Code general rules.
Under the participation exemption regime, capital gains on the transfer of shares are tax exempt provided the beneficiary holds at least 10%, directly or indirectly, of total capital or voting rights in the company from which the shares are transferred for a period of at least 1 uninterrupted year. The company from which the shares are transferred cannot be resident in a blacklisted jurisdiction and its assets cannot be directly or indirectly comprised of more than 50% of real estate located in Portugal.

Singapore Singapore does not tax capital gains.

Slovakia Individuals: 19% (from the tax base not exceeding 176.8 times the amount of the minimum living wage - EUR 41.445,456, and 25% (from the tax base exceeding the said EUR 41.445,456;


Corporations: 21%, or 15 % in case the revenue (income) does not exceed EUR 49.790;


In general, transfer of an ownership interest or shares in a Slovak company, or a membership interest in a cooperative with its seat in Slovakia is taxable, unless certain exemptions apply.


Sale of shares and ownership interests in Slovak and foreign companies (as of 2020 also simple joint-stock company, so-called "JAS" can be exempt from the corporate income tax if certain conditions are met (the sale arises no earlier than 24 months after the acquisition of at least 10% in the registered capital of said company and the taxpayer is not an individual or a shelf company). This tax exemption does not apply to taxpayers in liquidation, and to the income from sale of shares/ownership interests in companies in liquidation, bankruptcy or restructuring.


Separate rules are applicable to derivatives and hedging derivatives.


New regulation extends the definition of "dividend" also to:


i. usage of retained earnings after tax for creation of "capital fund of contribution"


ii. redistribution of reserve fund resources among shareholders, in the same part as they were created from retained earnings after tax.


Dividends distributed out of profits generated from 1 January 2004 until 31 December 2010 are not subject to any tax or national health insurance contributions.


Dividends distributed out of profits generated from 2011-2012 to individuals are subject to health insurance contribution at the rate of 10% and limited by specific caps.


Dividends distributed out of profits generated from 2013-2016 to individuals are subject to health insurance contribution at the rate of 14% and limited by specific caps.


Dividends distributed out of profits generated from 2017 onwards to:


i. legal entities resident in Slovakia or in a treaty state are not subject to any tax


ii. individuals resident in Slovakia or in a treaty state, or dividends received by individuals resident in Slovakia from a treaty state are taxable at 7%


iii. legal entities or individual's resident in a non-treaty or dividends received by Slovak residents from a legal entity in a non-treaty state are taxable at 35%.


The taxation of an income in Slovakia can be adjusted based on the existence of a relevant double tax treaty.

Spain Personal Income Tax (PIT).
It depends on the amount of the capital gain.
It could range from a tax rate of 19% to 28%.
For example, the tax rate will be 19% for capital gains up to €6,000, 21% for capital gains between €6,000 and €50,000, 23% for capital gains between €50,000 and €200,000, 27% for capital gains between €200,000 and €300,000 and 28% for capital gains above €300,000.

Certain capital gains are exempt from PIT.
For example, when the capital gain arises from the transfer of the principal residence and the amount of the capital gain is invested in the purchase of a new principal residence or when the capital gain arises from the transfer of a principal residence and the seller is over 65 years of age.

Corporate Income Tax (CIT).
As a general rule, capital gains are taxed at the rate of 25%.
Certain capital gains are exempt from CIT.
For example, a 95% exemption can be applied to capital gains resulting from the transfer of shares when the transferring entity holds more than 5% of the share and the entity has held the shares for more than 12 months.
The effective tax rate applicable shall be 1.25%.

United Arab Emirates Information unavailable or not applicable

Austria 27.5% on dividends; however, this depends on group structure and applicable double taxation treaties.

Brazil Dividends both to residents or non-residents are exempt of corporate and withholding taxes.

China Information unavailable or not applicable

Czech Republic Information unavailable or not applicable

England & Wales The payment of dividends by a UK subsidiary to a foreign parent does not attract any UK withholding taxes under UK domestic law.
Any dividends received by a UK company would generally be exempt from taxation in the hands of the UK company.

France For individuals: On dividends income, individuals are subject to (i) personal income tax at a 12.8% flat-rate tax and (ii) social contributions at a 17.2% rate (i.e., an overall tax rate of 30%). The taxpayers may also elect for a taxation at the progressive income tax rates if more beneficial. If any, dividends income will be subject to (i) personal income tax at the progressive scale up to 45%, after a 40% tax allowance upon the dividends income, and (ii) social contributions at a 17.2% rate. This election is global for all equity revenue of a year (i.e., dividend, interest and capital gain)

For companies: On dividends income, companies are in principle subject to the CIT at the standard rate of 25%. However, French parent companies holding at least 5% of the share capital of a subsidiary for two years, may benefit from a CIT exemption amounting to 95% of the subsidiary's. Dividends may benefit from this regime as from the first year if the Parent company take the commitment to keep shares at least two years. Thus, only 5% will remain liable to tax, which leads to an effective CIT rate of 1.25%. In case of French tax group, the CIT exemption is equal to 99% of the subsidiary’s dividends, so an effective tax rate of 0,25%. Also applicable to dividends from EU subsidiaries under certain conditions.

Germany Information unavailable or not applicable

Hong Kong None.

Hungary Dividend income is taxable at 15% PIT, and no tax base addition has to be applied. An additional 13% social tax is payable on dividend income if certain conditions are not met, but only up to a relatively low cap.
Dividend income should be reported in the annual tax return, and the taxes on dividend income have to be paid when the annual tax returns are filed.

Ireland Information unavailable or not applicable

Italy Individuals

For dividends received as of January 1, 2018, the 26% withholding tax applies, regardless of the size of the shareholding held.

However, for distributions of profits resolved from January 1, 2018 to December 31, 2022 and formed from profits produced up to the financial year current on December 31, 2017, the previous taxable percentages continue to apply:
- 40% of the dividend if the profits were produced up to the financial year current on December 31, 2007;
- 49.72% of the dividend if the profits were generated from the financial year following that in progress on December 31, 2007 until the financial year in progress on December 31, 2016;
- 58.14% if the profits are formed from the financial year following the one in progress on December 31, 2016 until the financial year in progress on December 31, 2017

Companies

Dividends received by Italian corporations deriving from holdings in companies resident in Italy for fiscal purposes are taxed at 5% of their amount (since 95% is excluded from taxation).

Netherlands The rate is 15% to be withheld by the distributing company. However, in case the recipient of the dividends is located outside of the Netherlands, there may be exemptions or refunds applicable

Poland Information unavailable or not applicable

Portugal As a rule, dividend payments are subject to a domestic withholding rate of 25%.
Under the participation exemption regime, profits distributions are tax exempt provided the beneficiary holds at least, directly or indirectly, 10% of total capital or voting rights of the distributing company for a period of at least 1 uninterrupted year. The subsidiary shall not be covered by the tax transparency regime neither resident in a blacklisted jurisdiction and should be subject to and not exempt from Corporate Income Tax or similar tax with a rate not lower than 12.6%.

Singapore Generally, no withholding tax is imposed on dividends paid by companies resident in Singapore.

Slovakia Information unavailable or not applicable

Spain Personal Income Tax (PIT).
It depends on the amount of the dividends received.
It could range from a tax rate of 19% to 28%.
For example, the tax rate will be 19% for dividends up to €6,000, 21% for dividends between €6,000 and €50,000, 23% for dividends between €50,000 and €200,000, 27% for dividends between €200,000 and €300,000 and 28% for dividends above €300,000.

Corporate Income Tax (CIT).
As a general rule, dividends received from a subsidiary company are taxed at the rate of 25%.
Certain dividends are exempt from CIT.
For example, a 95% exemption can be applied to dividends received from a subsidiary company in which the holding company holds more than 5% of the share capital (or shares with a value of more than €20M) and the holding company has held the shares for more than 12 months.
The effective tax rate applicable shall be 1.25%.

United Arab Emirates Information unavailable or not applicable

Austria Depending on individual circumstances, several tax advantages aiming at inter alia tech companies may be available.

Brazil Federal Law No. 11.196/2005 grants tax benefits for company which work with R&D and Technological Innovation.
In a summary, the benefits are:
(I) Deduction of operating expenses incurred with R&D designed for technological innovation;
(II) 50%-cut of Excise Tax on acquisitions of machinery, devices and instruments for R&D in technology;
(III) Full depreciation, for tax purposes, of fixed assets used for R&D in technology in the year of the assets’ acquisition;
(IV) Full amortization, for tax purposes, of intangible assets exclusively related to R&D activities aimed at technological innovation in the year of the assets’ acquisition;
(V) Deductions of operating expenses incurred with the employment of researchers and professionals exclusively dedicated to R&D.

China A company (including a foreign invested one) qualifying as a high-tech company may enjoy a reduced corporate income tax rate of 15%.

Czech Republic In the Czech Republic, this area is governed by GDPR. Moreover, the new Czech Law on Processing Personal Data is effective since April 2019 that specifies the general rules more in detail and lays down several differences from the general regime under GDPR. For example, controllers are relieved from certain obligations (including informing the data subjects) in case of data processing for purposes of journalism, and age limit relating to conditions applicable to child's consent in relation to information society services has been set to 15 years. Further, this adaptation legislation limits/precludes fines against public institutions.

There is no general requirement to notify planned or ongoing data processing to the Office for Personal Data Protection. The controller, however, must notify (inform) the processing to the data subjects.

Nevertheless, specific situations can occur where notification to, consultation with, or authorisation from the Office is required.

On the other hand, GDPR has introduced a notification requirement in case of a personal data breach (unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons). Such breaches must be notified to the Office for Personal Data Protection within 72 hours (in case this timeframe is not met, such delay has to be justified), and, depending on the severity of the breach, to the data subjects whose data have been affected by the breach.

England & Wales Research & Development (R&D) tax relief: enhanced corporation tax relief for expenditure incurred by companies on innovative science or technology projects.

From 1 April 2024, two R&D tax reliefs are available (although a company cannot claim both) in respect of the same expenditure):

Merged scheme R&D expenditure credit (RDEC): a 20% 'above-the-line' (taxable) credit. For companies paying the main rate of corporation tax, the cash benefit is 15%; for those paying the small profits rate, the cash benefit is 16.2%.

Enhanced R&D intensive support (ERIS): loss-making R&D-intensive small or medium-sized enterprises (SMEs) can either claim an enhanced deduction of 186% of qualifying expenditure in calculating their adjusted trading loss or claim a payable tax credit worth up to 14.5% of the surrenderable loss. A SME is 'R&D-intensive' if its R&D expenditure is at least 30% of its total expenditure.

Patent Box regime: companies with UK or EU patents may be eligible for an effective corporation tax rate of 10% in the UK on revenues derived from qualifying patents (subject to certain requirements being met).

France Companies can benefit from two tax mechanisms:
- Research & Development tax credit (R&D tax credit) and Innovation tax credit :
- R&D tax credit: Companies carrying out research activities can benefit from a R&D tax credit. The R&D tax credit, determined on each calendar year, is equal to 30% of the eligible research expenses incurred during the calendar year, up to EUR 100 million, and 5% beyond this amount.
- Innovation tax credit: SMEs carrying out innovation activities can also benefit from an innovation tax credit. The innovation tax credit, determined on each calendar year, is equal to 30% of the eligible innovation expenses incurred during the calendar year, up to EUR 400 000.

Patent Box: Any company subject to CIT in France that sells, licenses or sub-licenses intellectual property rights that qualify as intangible fixed assets may benefit from a reduced CIT rate of 10% on the net income from the said sales, licenses or sub-licenses. A “nexus” ratio is applied on this net income in order to determine the portion benefiting from the 10% rate.

Germany No special tax regime or tax benefits.

Hong Kong No special tax regime or tax benefits.

Hungary Tax credit shall be granted to taxpayers for investment projects
- valued at 50 million forints or more at current prices, implemented by small enterprises,
- valued at 100 million forints or more at current prices, implemented by medium-sized enterprises;
- for investment projects valued at 100 million forints or more at current prices, implemented in a free enterprise zone.

Tax credit may be claimed on condition that the investment qualifies as an initial investment:
a) implemented by a small and medium-sized enterprise, or
b) realized by a large company in the Észak-Magyarország, Észak-Alföld, Dél-Alföld, Dél-Dunántúl, Közép-Dunántúl, Nyugat-Dunántúl or Pest planning and statistical district.

Ireland Research and Development (R&D) Tax Credit / Capital Expenditure Tax Relief — a company can claim a 25% tax credit for expenditure on R&D carried on within the EEA. This can be combined with the normal business deduction for such R&D expenditure (at an effective rate of 12.5%), which results in a tax rate of 37.5%.

Income tax relief can also be made available to 'key R&D employees'. This means a company engaged in R&D activities can surrender some of its R&D credit to key employees so that their income tax liability is reduced by the amount surrendered (subject to not reducing the key employee's effective rate of tax to below 23%).
Write-down of Cost of Acquiring Intellectual Property — companies that acquire IP can deduct the cost of that acquisition against taxable profits. The deduction is available as a capital allowance (tax depreciation) and the cost is written-off over a number of years. The relief may be claimed when the IP is acquired from a third party and intra-group, subject to certain limitations. Further, the capital allowances claimed cannot exceed 80% of the company's taxable profit.
Knowledge Development Box — this is a form of patent box, and under the regime, profits derived from 'qualifying IP' will be subject to an effective rate of corporation tax of 6.25% (subject to certain requirements being met).

Italy Bonus for investments in R&D activities, technological innovations, and patent box.

For R&D activities a tax credit amount of 10% of the eligible expenses, up to a maximum of EUR 5 million.

For technological innovation activities, the tax credit is recognised separately at a 10% rate of the relevant basis of calculation, up to a maximum of EUR 2 million. For the achievement of an ecological transition or digital innovation 4.0 objective, the credit measure increases to 15%.

These tax credits are non-taxable tout court.

Patent box relief consists in the possibility of increasing by 110% the deduction of costs incurred in relation to the eligible intangible assets.

Netherlands R&D deductions, innovation activities, tax/patent box.

Under the Dutch innovation box regime, qualifying income from research and development activities are taxed at an effective rate of 9% rather than the statutory corporate income tax rate of 19%, 25%, 8%. Moreover, tax incentives can be applicable when attracting high-skilled labor from abroad.

Poland Research & Development (R&D) tax relief that can decrease a company's tax bill by an additional deduction of eligible R&D expenses from a company's tax base. The additional deduction amounts to:

(i) 100% of eligible expenses - for all companies;

(ii) 150% of eligible expenses - for companies simultaneously having the status of R&D Centre and the status of a micro entrepreneur, small entrepreneur, or medium-sized entrepreneur;

(iii) 100% of eligible expenses for obtaining and maintaining a patent, a utility model protection right, an industrial design registration right defined by a bill and 150% of the rest eligible expenses- for other companies which have the status of an R&D Centre.

The Polish Investment Zone is an incentive that provides an exemption from CIT for companies which carry out certain new investments. The value of incentive (the amount of tax that is subject to exemption) is a derivative of the amount of investment costs incurred by the company.

Portugal Possibility of a Research & Development (R&D) tax credit (SIFIDE) - tax incentive applicable to corporate taxpayers that consists of a tax deduction to companies’ tax burden of a certain amount of expenses incurred in the current year, with the possibility of a deferral up to 8 following tax years. This benefit allows a tax deduction of up to 82.5% for companies that have not invested in R&D in the last two years. This incentive is subject to pre-approval from the competent Portuguese authority.
There is also a Special Tax Regime to Support Investment (RFAI) - tax incentive applicable to corporate taxpayers who satisfy certain requirements and who develop a specific activity foreseen in the Portuguese tax law, which entitles to tax benefits (such as deductions, exemptions, or reductions) at the level of Corporate Income Tax, Municipal Property Tax, Property Transfer Tax as well as Stamp Duty.

Singapore Tax Exemption Scheme for New Start-Up Companies:

From YA 2020 onwards, new qualifying companies (where any YA of the first three YAs falls in or after YA 2020) will be given a 75% tax exemption on the first S$100,000 of normal chargeable income and a further 50% tax exemption on the next S$100,000 of normal chargeable income for each of the first three consecutive years of assessment.

Partial Tax Exemption for Companies:

From YA 2020 onwards, qualifying companies will be eligible for partial tax exemptions to a maximum of S$102,500 per YA.

Tax Deductions for Research & Development (R&D) Expenditure:

Subject to eligibility, for YA 2024 to 2028,

• where R&D is conducted wholly in Singapore (in-house), (i) tax deduction of 100%, (ii) additional tax deduction of 300% on the first S$400,000 on (a) staff costs (excluding directors’ fees) and (b) consumables, and (iii) additional tax deduction of 150% on the balance of qualifying R&D expenditure in excess of S$400,000;

• where R&D is conducted wholly in Singapore but outsourced, (i) tax deduction of 100%, (ii) additional tax deduction of 300% on the first S$400,000 on (a) 60% of fee paid, or (ii) actual staff costs (excluding directors' fees) and consumables incurred if the amount is more than 60% of fee paid, and (iii) additional tax deduction of 150% on the balance of qualifying R&D expenditure in excess of S$400,000; and

• where R&D is carried out overseas, (i) 100% tax deduction for R&D related to trade, (ii) but no tax deduction if R&D conducted is not related to trade.

Pioneer tax incentive (PC) and the Development and Expansion Incentive (DEI):

Application for the PC or DEI is open to companies that are prepared to make significant investments in contribution to the economy or in advancement of capabilities towards globally leading industries.

In addition, to be eligible for consideration of PC, companies must introduce technology, skillsets or knowhow into an industry that are substantially more advanced than the average prevailing in Singapore. The company must also carry out new, pioneering activities that have not been undertaken by other companies at a scale that is substantive in economic contribution.

An approved company under the PC or DEI is eligible for a corporate tax exemption or a concessionary tax rate of 5% or 10%, respectively, on income derived from qualifying activities.

Enterprise Innovation Scheme (EIS):

Under the EIS, enhanced/new tax deductions and/or allowances (collectively referred to as “enhanced deductions”) are granted on qualifying expenditure incurred on the following five qualifying activities: (i) qualifying R&D undertaken in Singapore; (ii) registration of intellectual property (IPs); (iii) acquisition and licensing of IP rights (IPRs); (iv) training; and (v) innovation projects carried out with polytechnics, the Institute of Technical Education (ITE) or other qualified partners.

Businesses that carry on a trade or business will be able to enjoy enhanced deductions on up to S$400,000 of qualifying expenditure incurred for each qualifying activity (i) to (iv), and up to S$50,000 of qualifying expenditure incurred for the qualifying activity (v). The qualifying expenditure cap for each qualifying activity is applied on a YA basis and cannot be combined across YAs.

The deductions/ allowances granted under the EIS are in addition to the base deductions/ allowances allowable under prevailing income tax rules. The total deductions/ allowances granted are in effect 400% per dollar of qualifying expenditure (up to the applicable cap) for each qualifying activity.

In lieu of tax deductions/ allowances, eligible businesses may also, subject to conditions, opt to convert up to S$100,000 of the total qualifying expenditure across all the qualifying activities for each YA into a cash payout at a conversion rate of 20%

Capital Allowances for Acquisition of IP Rights:

Companies can claim writing-down allowances on capital expenditure incurred up to the last day of the basis period for YA 2025 to acquire approved intellectual property rights for use in their trade or business. "Capital expenditure" excludes legal fees, registration fees, stamp duly and other costs related to the acquisition of the intellectual property rights.

Slovakia Certain advantages can be provided in the form of investment incentives (eg to start new production or the provision of services); these incentives are subject to the special regulation in the State Aid Act and can be provided in the form of cash or tax relief. Certain corporate income tax relief can be also provided under the Act on Investment Incentives and the Act on Research and Development Incentives.

Patent Box – this new form of tax advantage was introduced as of January 2018. Under this special tax regime, it will be possible to be exempt from income tax up to 50% of any revenues derived in the form of license fees relating to the provision of intangible assets resulting from the taxpayer’s own development activities in Slovakia (patents, utility models, or software). The tax exemption, however, only applies to taxable periods in which the taxpayer depreciates the capitalised costs relating to the development of these intangible assets (eg inventions protected by patent, the technical solutions protected by utility model or the software). In addition, a separate tax regime was introduced for revenues derived from the sale of products manufactured on the basis of an invention protected by patent or a technical solution protected by utility model – such revenues will also be exempt from the income tax.

Spain Corporate Income Tax (CIT).
- Research & Development (R&D) tax relief.
A CIT credit is available for companies incurring qualifying expenditure on R&D projects.
The deduction rate ranges from 8% to 42%.

- Patent Box tax relief.
A CIT relief of taxable base can be applied to income from the exploitation of certain intangible assets such as patents.
The reduction rate is 60%.

-Tax benefits Start-ups.
They can apply the reduced CIT rate (15%) during the first tax period in which they have positive taxable income and the following three tax periods.
They are exempt from the obligation to make payments in instalments during the two tax periods following the first one in which they obtain positive taxable income.
Possibility of requesting deferral of tax debts during the two tax periods following the first one in which a positive tax base is obtained, for 12 months (for the first period) and 6 months (for the second period), with waiver of guarantees and without accrual of interests on arrears. However, the self-assessment must be submitted within the voluntary filing period, and the taxpayer must be up to date with his tax obligations on the date of the application.

Personal Income Tax (PIT).
- Tax benefits Start-ups.
Improvement of the deduction for investment in new or recently created companies by increasing the deduction rate from 30% to 50%, as well as the base of the deduction from €60,000 to €100,000, the base being formed by the acquisition value of the shares or holdings subscribed in these entities. This deduction will only be applicable if the shares or holdings were acquired at the time of incorporation or in a capital increase within 5 years of incorporation (7 years for companies in special sectors such as biotechnology, energy and strategic sectors).

United Arab Emirates No special tax regime or tax benefits.