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CONTENTS
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AUSTRIA
INCOME TAX RATES 2010
Individuals
Taxable income (EUR)
up to 11,000
from 11,001 – 25,000
from 25,001 – 60,000
over 60,000
Tax rate (%)
0
36.5
43.2
50
The above tax rates apply to all income (including capital gains realised in the course of
a business, speculative gains etc.), except dividend income and most savings income.
The same rates apply to both residents and non-residents. However, non-residents have
to add EUR 9,000 to their tax base (especially for income that has not been taxed by
way of withholding).
Companies
Corporations are taxed on their gross income at the corporate level and are subject to
Austrian corporate income tax at a flat rate of 25%. Corporations are obliged to pay
annual minimum income tax (AG: EUR 3,500; GmbH: EUR 1,750) even when making
losses. The same rates apply to both resident and non-resident companies. Companies
linked in a financial hierarchy can under specified circumstances constitute a group for
tax purposes. The taxable profits or losses of the members of a group are added to
those of the taxable company in the group. Losses of non-resident companies can be
deducted as well as goodwill amortisation of resident companies.
VALUE ADDED TAX (VAT)
VAT covers any entrepreneur who independently carries on a business in Austria. The
standard VAT rate is 20%. A reduced rate of 10% is imposed on rents of land and
buildings for residential purposes (including hotel accommodation), transport of
passengers, etc.. Zero rate (0%) is applied for certain specific items (i.e. exported goods
and services).
CAPITAL GAINS TAX (CGT)
In principle losses from the disposal of shares in a company (shareholding of at least
1% during the preceding five years) are taxed at one half of the effective rate on the
taxpayer’s total income. Holding companies are privileged under certain circumstances,
interest expenses are mostly deductible.
LOSSES
In principle losses may be carried forward without time limit. As a rule, losses carried
forward can only be set off against 75% of the income of the current year. Excess losses
may be carried forward to subsequent tax years. Losses carried forward may be lost
after a substantial change in ownership.
TREATY NETWORK
More than 80 countries.
WITHHOLDING TAX (non-residents)
Dividends: 25% (unless reduced/exempt under Parent–Subsidiary Directive or the
relevant treaty)
Interest:
20% (until 30/6/2011, afterwards 35%, particularly if paid to non-resident
EU individuals)
Royalties: 20% (unless reduced/exempt under Interest–Royalty Directive or the
relevant treaty)
Contact:
Gottfried Maria Sulz
gottfried.sulz@tpa–horwath.com
TPA Horwath Wirtschaftstreuhand und Steuerberatung GmbH
Praterstrasse 62–64
1020 Vienna
Austria
Tel: +43 1 588 35 331
www.tpa–horwath.com
Europe, Middle East and Africa Tax facts 2010
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BAHRAIN
BELGIUM
INCOME TAX RATES 2010
Individuals
No income tax is payable.
INCOME TAX RATES 2010
Individuals
Companies
No income tax is payable.
VALUE ADDED TAX (VAT)
Not applicable
CAPITAL GAINS TAX (CGT)
Not applicable
LOSSES
Not applicable
TREATY NETWORK
Not applicable
WITHHOLDING TAX (non-residents)
Dividends: 0%
Interest:
0%
Royalties: 0%
Taxable income (EUR)
up to 7,900
from 7,901 – 11,240
from 11,241 – 18,730
from 18,731 – 34,330
over 34,330
Tax rate (%)
25
30
40
45
50
Supplemented by a municipal surcharge; some items of income are taxed at a separate
rate.
Companies
Taxable income
Basic tax rate
Tax rate (%)
33.99
Progressive lower rates for companies with taxable income up to EUR 322,500; not
applicable to financial companies, or for companies whose shares are at least 50%
owned by one or more companies.
VALUE ADDED TAX (VAT)
21% on majority of sales of goods/services; reduced rates (6%/12%) on certain specific
items.
CAPITAL GAINS TAX (CGT)
Individuals
No taxation if not engaged in business activities, with some exceptions, e.g. speculative
transactions, sale of immovable property within five years of the acquisition.
Companies
Tax paid at the company tax rate. Rollover relief for gains on fixed assets held for more
than five years and subject to reinvestment. Capital gains on shares are exempt if the
dividends relating to such shares qualify for the participation exemption.
LOSSES
Carry forward of losses is unlimited. No carry forward if there is a change in ownership
which does not meet justified financial and economic needs.
TREATY NETWORK
88 countries.
WITHHOLDING TAX (non-residents)
Dividends: 25%/15%/0% (when distributed to companies located in Belgium, EU or
in a country with double tax treaty and holding a participation of at least
10% during one year)
Interest:
15%
Royalties: 15%
Contact:
Fuad Alkaabi
info@horwathbahrain.com
Horwath Bahrain
P.O. Box 484
Building 12, Road 3201, Manama 332
Kingdom of Bahrain
Tel: +973 17 822440
www.horwathbahrain.com
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Europe, Middle East and Africa Tax facts 2010
Contact:
Jenny Putzeys
jenny.putzeys@callens.be
Callens Pirenne & Co
Jan Van Rijswijcklaan 10
2018 Antwerpen
Belgium
Tel: +32 3 248 50 10
www.callens–theunissen.com
Jiri Vanhuynegem
jvh@v–a.be
Vanhuynegem Associates
Floraliënlaan 2 bus 1
2600 Antwerpen
Belgium
Tel: +32 3 216 07 08
www.v–a.be
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BOTSWANA
BULGARIA
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (BWP)
Resident taxpayer
up to 30,000
from 30,001 – 60,000
from 60,001 – 90,000
from 90,001 – 120,000
over 120,000
Tax rate (%)
0
5
12.5
18.75
25
Taxable income (BWP)
Tax rate (%)
Non-resident taxpayer, trusts and estates
up to 60,000
5
from 60,001 – 90,000
12.5
from 90,001 – 120,000
18.75
over 120,000
25
Losses from a source of income other than farming cannot be set off against the profits
from another source of income. Such losses can however be carried forward for five
years for set off against income from the same source. Farming losses can be carried
forward indefinitely.
Companies
Taxable income
Resident company non-manufacturing
basic
additional
Resident company manufacturing
basic
additional
Non-resident company
Tax rate (%)
15
10
5
10
25
Taxable income
All income
Tax rate (%)
10
Companies
Taxable income
All income
Tax rate (%)
10
VALUE ADDED TAX (VAT)
Standard rate – 20%
Reduced rate – 7% for accommodation provided as part of tourist packages
Zero rate – export, supplies of goods and services within the EU, other supplies listed in
the VAT Act.
CAPITAL GAINS TAX (CGT)
As a general rule, sale of shares in joint stock companies, limited liability companies and
partnerships are taxable at 10%. Disposal of shares in stock exchange listed companies
in EEA countries by legal persons are exempt from tax.
LOSSES
Loss set-off is possible. Losses can be carried forward for a maximum of five years
TREATY NETWORK
66 countries.
WITHHOLDING TAX
Dividends: Exempt for companies resident in Bulgaria, EU and EEA
5% elsewhere unless reduced by relevant treaty
Interest: 10% unless reduced by relevant treaty
Royalties: 10% unless reduced by relevant treaty
Withholding tax paid on dividends may also be set off against that year's additional
company tax. However, excess withholding tax paid on dividends in any year can not
be carried forward to set off additional company tax of any future year.
VALUE ADDED TAX (VAT)
10% on the majority of goods/serives; reduced or zero rate on certain specific items.
CAPITAL GAINS TAX (CGT)
Individuals
Taxable income (BWP)
up to 15,000
from 15,001 – 60,000
from 60,001 – 90,000
from 90,001 – 120,000
over 120,000
Companies
Tax rate (%)
0
5
12.5
18.75
25
25
LOSSES
Losses are carried forward for five years after which they fall away. All sources of income
in the hands of a company are treated as one singular source.
TREATY NETWORK
8 countries.
WITHHOLDING TAX (non-residents)
Dividends: 15% non-resident and non-residents
Interest:
15%
Royalties: 15%
Contact:
Guru Gurumoorthi
guru.gurumoorthi@gurugroup.bw
Horwath Gurugroup Professional Services (Pty) Ltd Plot
1278 Old Lobatse Rd P.O.Box 1816 Gaborone Botswana
Tel: +267-3912805
www.gurugroup.bw
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Contact:
Georgio Kandilarov
georgio.kandilarov@tpa–horwath.bg
TPA Horwath OOD
16, Sveta Nedelya Square, Floor 3
1000 Sofia
Bulgaria
Tel: +3592 981 6645/+3592 981 6635
www.tpa–horwath.com
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CROATIA
CYPRUS
INCOME TAX RATES 2010
Individuals
Taxable income (HRK)
up to 43,200
from 43,201 – 108,000
from 108,001 – 302,400
over 302,400
INCOME TAX RATES 2010
Individuals
Tax rate (%)
15
25
35
45
Tax rate (%)
0
20
25
30
Companies
Companies
Taxable income
All income
Taxable income (EUR)
up to 19,500
from 19,501 – 28,000
from 28,001 – 36,300
over 36,300
Tax rate (%)
20
Taxable income
All income
Tax rate (%)
10
VALUE ADDED TAX (VAT)
23% on majority of goods and services; 10% on tourism and accommodation services,
certain magazines and newspapers; 0% on certain specific items and exports.
VALUE ADDED TAX (VAT)
15% on majority of sales of goods/services; reduced or zero rate on certain specific
items.
CAPITAL GAINS TAX (CGT)
There is no separate CGT. Capital gains are included in the taxable base of the income
of the resident. Gains on non-business assets of individuals are exempt. Capital gains of
non-residents are exempt from taxation.
CAPITAL GAINS TAX (CGT)
20% is imposed only on gains on disposal of immovable property located in Cyprus or
on disposal of shares of companies with immovable property located in Cyprus.
LOSSES
Both individual and company tax losses can be offset against income. Losses can be
carried forward for five years. Losses cannot be carried back.
TREATY NETWORK
50 countries.
WITHHOLDING TAX (non-residents)
Dividends: 0%
Interest:
15%
Royalties: 15%
Contact:
Kresimir Lipovscak
kresimir.lipovscak@tpa–horwath.hr
TPA Horwath d.o.o.
Grand Centar, Petra Hektorovica 2
10 000 Zagreb
Croatia
Tel: +385 1 488 2 555
www.tpa–horwath.hr
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Europe, Middle East and Africa Tax facts 2010
LOSSES
Can be offset against other sources of income, and can be carried forward indefinitely.
Losses of a company can be set off against profits of another company in the same
group (group of Cyprus tax–resident companies). Worldwide losses can be set off
against taxable income of the same year or carried forward.
TREATY NETWORK
45 countries.
WITHHOLDING TAX (non-residents)
Dividends: 0%
Interest:
0%
Royalties: 0% (10% on royalties used in Cyprus. 5% on film and TV royalties).
Contact:
Yiannis Demetriades
YiannisD@horwathdsp.com
Horwath DSP Ltd
Chartered Certified Accountants
8 Stassinos Avenue
P.O.Box 22545 Nicosia 1522
Cyprus
Tel: +357 227 556 56
www.horwathdsp.com
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CZECH REPUBLIC
DENMARK
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income
All income
Tax rate (%)
15
The low tax rate is compensated by an increase in the tax base (tax base includes the
amount of social and health insurance paid from gross salary by an employer).
Taxable income
Companies
Certain investment funds and mutual funds
Tax rate (%)
19
5
A Czech limited partnership is treated like a company with regard to the proportional
income of its limited partners. In an unlimited partnership, a partner’s pro rata income
is subject to income tax at the individual’s rate (if a partner is a corporation then the
pro rata income is subject to corporate income tax at the corporate rate).
VALUE ADDED TAX (VAT)
The standard VAT rate is 20%. A reduced rate of 10% or a zero rate is applied on
specific goods and services.
CAPITAL GAINS TAX (CGT)
Individuals
Capital gains are generally taxed at standard rate (flat rate of 15% in 2010). Disposal of
real estate or shares is tax free provided that respective conditions are met.
Companies
Capital gains are taxed at the standard corporate tax rate. Certain capital gains are
exempt provided conditions similar to the Parent Subsidiary Directive conditions are
met (10%, 12 months etc.).
LOSSES
Losses of individuals and companies may be carried forward and utilised for a limited
period of five years provided general conditions are met (e.g. the ‘same business’ test).
No loss carry back available.
TREATY NETWORK
79 countries.
WITHHOLDING TAX
Dividends: 15% (unless reduced/exempt under EC Directive or the relevant tax treaty)
Interest:
15% (unless reduced/exempt under EC Directive or the relevant tax treaty)
Royalties: 15%, 5% for finance lease (unless reduced/exempt under the relevant tax
treaty)
Contact:
Jan Lamacˇ
Jan.lamac@tpa-horwath.cz
TPA Horwath Notia Tax s.r.o.
Mánesova 28, 120 00 Prague 2
Czech Republic
Tel: +420 222 826 321
www.tpa–horwath.cz
Europe, Middle East and Africa Tax facts 2010
Taxable income (EUR)
up to 5,700
from 5,701 – 52,300
over 52,300
Tax rate (%)
0
37.3
52.2
In addition, a social contribution (a duty) in the amount of 8% is levied. However, this
amount is deductible.
Companies
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Companies
Taxable income
All taxable income
Tax rate (%)
25
VALUE ADDED TAX (VAT)
25% unless specially exempted (e.g. insurance, banking and certain financial
activities).
CAPITAL GAINS TAX (CGT)
Individuals
Generally included in the aggregate income subject to progressive rates (‘income from
capital’ or ‘other income’ as the case may be). No indexation applies.
Companies
Tax paid at company tax rate, i.e. there is no separate CGT. Income and capital gains
are generally pooled and taxed together.
LOSSES
Losses may be carried forward indefinitely. No carryback is permitted. For companies,
the carry forward may be restricted upon changes in ownership or settlement with
creditors.
TREATY NETWORK
73 countries.
WITHHOLDING TAX (non-residents)
Dividends: 28% or 0% when paid to a company, which owns at least 10%
Interest:
30% or 0% when paid to a company/individual
Royalties: 30%
Various domestic exemptions and relief under either EU Directive or tax treaties apply.
Contact:
Hans Olsen
h.olsen@horwath.dk
Strandvejen 58
2900 Hellerup
Denmark
Tel: +45 39 29 25 00
www.horwath.dk
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EGYPT
ESTONIA
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (EUR)
up to 1,726
over 1,726
Taxable income (EGP)
Tax rate (%)
up to 5,000
0
from 5,001 – 20,000
from 20,001 – 40,000
10
15
over 40,000
20
Resident foreigners (i.e. staying in Egypt for more than 183 days in a calendar year)
receieve the same tax treatment as locals. Non-resident foreign employees are taxed at
a rate of 10% without any deductions in accordance with Article 11 of the Tax Law.
Companies
Taxable income
Tax rate (%)
Corporate income
20
Oil exploration and production companies
40.55
Foreign branches receive the same local corporate tax treatment.
VALUE ADDED TAX (VAT)
Sales Tax: General Sales Tax (G.S.T) is levied on locally manufactured goods or
imported goods with rates varying between 5% to 10% on most goods except goods
exempted by a special provision. Sales Tax Authority website: www.salestax.gov.eg
(Arabic/English).
CAPITAL GAINS TAX (CGT)
Not applicable.
Companies
Taxable income
Profit distributed to owners
WITHHOLDING TAX
Withholding tax is applied to any ‘onshore’ payments such as commissions, brokerage,
purchases, supplies, contracting or services over EGP 300 paid to private sector entities
in Egypt. In accordance with Article 59 of the Tax Law, the withholding tax rate applied
is as follows:
Nature of activity
Contracting and supplies
Services
Professional fees and commissions
Withholding tax rate (%)
0.5
2
5
A tax rate of 20% is applied to the amounts paid by the individual companies or any
legal entities resident in Egypt to non-residents without any deductions. This includes
interest, royalties (except those related to manufacturing), services and payments for
athletic activity and for artists.
Tax rate (%)
21
Corporate profit is taxed when it is distributed to shareholders. Income tax (21/79 of
net payment) is payable from amounts paid out as dividends, on decrease of share
capital, redemption of shares and on liquidation of a business in an amount which
exceeds contributions made to share capital.
VALUE ADDED TAX (VAT)
Standard rate: 20%
Reduced rate of 9% is applicable for:
books
medical equipment and pharmaceutical goods
periodical publications, excluding erotic pornographic and advertising
accommodation fees.
CAPITAL GAINS TAX (CGT)
Individuals – Estonian residents:
Resident company:
Non-resident company:
LOSSES
In accordance with Article Nos. 29 and 37 of the Executive Regulation, tax losses can
be carried forward for a period of five years, however no carry back of losses is allowed
as per article 55.
TREATY NETWORK
More than 45 countries.
Tax rate (%)
0
21
21%
0%
21% from profit received on sale of real estate
and shares of Estonian companies if more
than 50% of the company assets comprise
real estate properties located in Estonia, and
non-resident owns 10% or more of shares
0% In other cases.
LOSSES
Estonian residents can deduct losses incurred on sales of securities from taxable capital
gains in the following taxation periods and individual entrepreneurs can deduct losses
from business income within the next seven years.
TREATY NETWORK
44 countries.
WITHHOLDING TAX (non-residents)
Dividends: 0%
Interest:
21% on gap between actually paid and market interest rates
Royalties: 10%
Or reduced/exempt under relevant treaty and Royalty and Interest payment Directive.
ROYALTIES
Royalties payments to non-resident entities or individuals are taxed at 20% without any
deductions, subject to any preferential treatment allowed under any treaty for the
avoidance of double taxation.
Contact:
Dr Mohamed Hegazy
mhegazy@link.net
Crowe Dr. A. M. Hegazy & Co
6 Boulos Hannah Street - Dokki - Giza
12311 Giza - Egypt
Tel: +202 37600516/+202 37600517
www.crowehorwathinternational.com
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Europe, Middle East and Africa Tax facts 2010
Contact:
Leonid Agejev
leonid@larssen.ee
Larssen CS
13 Narva mnt.
Tallinn 10151
Estonia
Tel: +372 614 3090
www.larssen.ee
Vadim Donchevski
donoway@donoway.ee
Donoway Assurance
13 Narva mnt.
Tallinn 10151
Estonia
Tel: +372 68 25 750
www.donoway.ee
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GEORGIA
FRANCE
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (EUR)
up to 5,875
from 5,876 – 11,720
from 11,721 – 26,030
from 26,031 – 69,783
over 69,783
Tax rate (%)
0
5.5
14
30
40
Taxable income
All income
Tax rate (%)
20
Companies
Taxable income
All income
Tax rate (%)
15
VALUE ADDED TAX (VAT)
Companies
Taxable income (EUR)
up to 38,120
from 38,121 – 2,289,000
over 2,289,000
Page 14
Tax rate (%)
15
33.33
34.33
Standard rate 18% for the supply of goods or services in Georgia.
Zero rate for certain exports, supply of natural gas to electric power, foreign tour operators in
Georgia and others.
CAPITAL GAINS TAX (CGT)
Non applicable
VALUE ADDED TAX (VAT)
19.6% on majority of sales of goods/services; reduced or zero rate on certain specific
items.
LOSSES
May be carried forward and deducted from future taxable income for a limited period of 5
years.
SOCIAL TAXES
All income is subject to CSG (Contribution Sociale Généralisée) and CRDS
(Contribution au Remboursement de la Dette Sociale).
Capital incomes are in addition subject to Prélèvement Social and RSA (Revenu de
Solidarité Active).
Salary income: 8%
Capital gains and other capital revenues: 12.1%.
TREATY NETWORK
26 countries.
WITHHOLDING TAX
Dividends: 5%
Interest:
5%
Royalties: 0%
CAPITAL GAINS TAX (CGT)
Individuals
Taxable income (EUR)
up to 25,830
over 25,830
Tax rate (%)
12.1 (social)
12.1 + 18 (tax) = 30.1
Companies
In principle, capital gains are subject to corporate income tax at the standard rate
(33.33%). However, as from 1 January 2007, capital gains on shares may be exempt
from corporate income tax (except for a 5% lump sum subject to corporate income tax
at the standard rate) if the shares qualify as a ‘participation’ for accounting purposes or
for the participation exemption regime (i.e. the company holds at least 5% of the share
capital and the shares are held for at least two years (i.e. the company holds or
undertakes to hold them for at least two years)).
LOSSES
French tax losses can be carried forward indefinitely; they can be carried back three
years. Since 2009, CIT corresponding to losses carried back can be reimbursed
immediately.
TREATY NETWORK
145 countries.
WITHHOLDING TAX (non-residents)
Dividends: maximum rate at 25%, reduced at 18% or 0% (European Union)
according to international conventions between the countries
Interest:
maximum rate at 18%, reduced at 0% (European Union) according to
international conventions between the countries
Royalties: tax rate between 0–33.33% according to international conventions
between the countries
Contact:
Marc de Premare
mdepremare@horwath.fr
Horwath Audit France, Paris office
6, boulevard Bineau
92532 Levallois Perret - CEDEX France
Tel: + 33 1 41 05 98 40
Fax : + 33 1 40 89 03 49
www.horwath.fr
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Europe, Middle East and Africa Tax facts 2010
Contact:
Temuri Partskhaladze
gacc@caucasus.net
Georgian Audit and Consulting Company (GACC)
Room 29, 47 Kostava str.
Tbilisi 0179
Georgia
Tel: +995 32 984039
Fax: +995 99 501370
www.gacc.com.ge
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GERMANY
GREECE
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
up to 8,004
Standard income
tax rate (%)
0 (tax-free allowance)
Solidarity
surcharge (%)
0
Total tax
rate (%)
0
from 8,005 – 52,881
14 to 42
0.77 to 2.31
14.77 to 44.31
from 52,882 – 250,730
42
2.31
44.31
over 250,730
45
2.475
47.475
Taxable income (EUR)
Taxable income (EUR)
Tax rate (%)
Taxable income (%)
Salaried & Pensioners
Tax rate (%)
Others
up to 10,500
0
up to 12,000
0
from 10,501 – 12,000
15
Interest and dividend income is flat taxed at a 26.375% rate (25% +1.375% solidarity
surcharge).
from 12,001 – 30,000
25
from 12,001 – 30,000
25
from 30,001 – 75,000
35
from 30,001 – 75,000
35
Companies (nominal corporation tax rate 15% plus Solidarity Surcharge)
over 75,000
40
over 75,000
40
Corporation tax rate (%)
(Solidarity surcharge incl.)
15.83
Trade tax rate
(%)
7
Total (%)
Interest income is taxed at 10% for individuals.
22.83
Companies
Multiplier 400
(average)
15.83
14
29.83
Multiplier 490
15.83
Corporations
Multiplier 200
17.15
32.98
The trade tax multiplier varies from 200-490%. It depends on where the company is
located. Partnerships such as GbR or KG are not subject to corporation tax (but may be
subject to trade tax). Instead the company’s income is assigned to the shareholders.
VALUE ADDED TAX (VAT)
Regular VAT rate
Reduced VAT rate (e.g. food, newspaper, local transportation)
Some services such as banking services or non-profit making work
19%
7%
0
Tax rate (%)
24
20
a) S.A., LTD, JVs
b) G.P., L.P.
Dividends
a) Domestic payable to domestic shareholder * **
b) Domestic payable to foreign shareholder *
c) Foreign payable to domestic shareholder *
Tax rate (%)
10
As per DTT
Normal Income Tax Rate
* Conditions apply
** Dividend tax withheld can be offset against dividend tax of parent co.
CAPITAL GAINS TAX (CGT)
Shares in corporations
Individuals
Flat taxation at 26.375%
(25%+1.375% Solidarity Surcharge),
exemptions for shareholdings of
more than 1%.
Corporations
Profit on disposal of shares is
generally 95% tax exempt
Shares in
partnerships
Taxable income
but some
allowances
Taxable income
Real estate
After ten years
tax-free,
otherwise
taxable income
Taxable income
LOSSES
Tax losses can be offset against other income in the current year, or carried back and
offset against income of the former year to a certain extent. They can also be carried
forward indefinitely and offset against income of upcoming years to a certain extent.
TREATY NETWORK
88 countries.
Tax rate (%)
25
25
20
CAPITAL GAINS TAX (CGT)
From disposal of shares listed on a Stock Exchange: 0% if not distributed as dividends.
From disposal of shares not listed on a Stock Exchange: 5% on transaction value
payable upon completion of the sale. For companies, capital gains are subject to
normal income tax against which the 5% already paid is offset.
From disposal in holdings in non sa companies: 20% of capital gain.
In all cases special conditions, limitations and minimum tax values apply.
LOSSES
Companies can carry losses forward for a maximum of five taxable periods following the
year in which the losses were incurred. Losses incurred abroad in the current tax year can
be offset by profit gained abroad for the same tax year.
TREATY NETWORK
47 countries.
WITHHOLDING TAX (non-residents)
Income
Dividends
Interest
Royalties
VALUE ADDED TAX (VAT)
The standard rate is 19%. A reduced rate of 9% is applied on specific goods and services.
Solidarity surcharge (%)
1.375
1.375
1.100
Total tax rate (%)
26.375
26.375
21.100
WITHHOLDING TAX (non-residents)
Dividends: 10%; 0% to EU shareholders subject to certain conditions.
Interest:
10%; 0% to foreign investors.
Royalties: 20%; 0% to domestic companies
Contact:
Güenter Wagner
guenter.wagner@awt-horwath.de
AWT Horwath GmbH
Wirtschaftsprufungsgesellschaft
Leonhard-Moll-Bogen 10
81373 Munich
www.awt.de
Michael Schmitz
schmitz@horwath-frankfurt.de
HSA Horwath GmbH
Wirtschaftsprufungsgesellschaft
An der Dammheide 10
60486 Frankfurt am Main
Germany
www.horwath-frankfurt.de
Wolfgang Kirschning
wolfgang.kirschning@rwt-horwath.com
RWT Horwath GmbH
Wirtschaftsprüfungsgesellschaft
Pariser Platz 7
70173 Stuttgart, Germany
+49 711 319400-21
www.rwt-horwath.com
14
Europe, Middle East and Africa Tax facts 2010
Contact:
Edmond Airantzis , Pantaris Panayiotis
eairantzis@solcons.gr , solaeoe@otenet.gr
SOL s.a.
3, Fok. Negri
11257, Athens
Greece
Tel: +30 210 8691368
www.solae.gr
Europe, Middle East and Africa Tax facts 2010
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HUNGARY
IRAN
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (HUF)
up to 5,000,000
over 5,000,000
Tax rate (%)
17
32
The above tax rates basically apply to the taxable income from employment. Taxable
income means the gross salary increased with the amount of the social contributions
(27%). Other income (e.g. capital gains, gains on transfer of property, rent, income
from securities trading, dividends) is taxed at specified rates, generally at 25%. The
same rates apply to both residents and non-residents.
Dividend income of individuals is subject to tax at a rate of 25%. Gains of individuals
arising from the sale of shares in a company are taxed at a rate of 25%. Interest income
of individuals is taxed at a rate of 20%.
Companies
Taxable income
All income
Tax rate (%)
19
VALUE ADDED TAX (VAT)
VAT applies to any entrepreneur who carries on business in Hungary. The standard VAT
rate is 25%. A flat rate of 18% is imposed on milk, corn, flour and the products from
these. Also a 18% flat rate is imposed on central heating and accomodation. A flat rate
of 5% is imposed on medicines, books etc. Zero rate (0%) is applied for certain specific
items (e.g. exported goods and services).
CAPITAL GAINS TAX (CGT)
There is no separate CGT for companies. Capital gains are included in the corporate
income tax base and taxed at the regular rates. Dividend income of companies is not
subject to corporate income tax. Interest income and gains of companies arising from
the selling of shares in a company are taxed at 19% corporate income tax.
LOSSES
The losses can be carried forward without any restriction or time limit.
TREATY NETWORK
More than 60 countries.
WITHHOLDING TAX (non-residents)
Dividends: individuals: 25% (unless reduced/exempt under the relevant treaty)
companies: none
Interest:
individuals: 20% (unless reduced/exempt under the relevant treaty)
companies: none
Royalties: individuals: 0%
companies: none
Taxable income - monthly (Rials)
up to 4,166,667
from 4,166,668 – 7,666,667
from 7,666,668 – 12,500,000
from 12,500,001 – 25,000,000
from 25,000,001 – 87,500,000
over 87,500,000
Tax rate (%)
exempt
10
20
25
30
35
The basic salary subject to tax exemption is announced at the beginning of each
financial year (starting 21 March). At the time of printing, the 2010 exemption had not
been announced therefore the above information is based on the 2009 figures. Single
or married individuals are subject to the same tax rate. Dividends received by an
individual (income after 25% corporate tax) are not subject to the above mentioned
tax.
Companies or registered branch office of foreign companies
Taxable income
All income
Tax rate (%)
25
VALUE ADDED TAX (VAT)
3% on sales of most goods and services. Cigarettes 15%, Fuel 6.5% to 30%. VAT Law
applies from 22 September 2008.
CAPITAL GAINS TAX (CGT)
Individuals
Capital gains are taxed for individuals who are legally enforced to file annual tax returns
(there is no need for filing annual tax return by an individual whose income is salary).
Fixed low tax rate applies for capital gains; on property (4%), and on transfer of
shares/capital (listed company 0.05% of transaction value and 4% on nominal value for
other companies).
Companies
Companies (legal entity) pay corporate tax at 25% rate on taxable income being net
profit, after taking disallowed expenses into consideration (as stated in tax law and
regulations). Listed companies enjoy a 10% discount on above mentioned tax rate.
LOSSES
Carried forward losses (amount approved by tax office) can be deducted from
following years' profit.
TREATY NETWORK
38 countries.
WITHHOLDING TAX (non-residents)
Dividends: zero base
Interest:
5%
Royalties: 5% – 7.5%
Rent:
10% – 35% on 75% of amount rent
Contact:
Jószef Szemerédi
tpa@tpa–horwath.hu
TPA Horwath Consulting Kft.
Buday László u. 12.
1024 Budapest
Hungary
Tel: +36 1 345 45 00
www.tpa–horwath.hu
16
Europe, Middle East and Africa Tax facts 2010
Contact:
Abbas Hoshi
hb.iran@hoshiyar.com
Hoshiyar Behmand & Co.
130 Ghaemmagham Farahani Ave, (Fourth floor App 20/21)
P.O Box 15815-1619
Tehran – Iran
Telefax: +98-21-88843705/5
www.hoshiyar.com
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REPUBLIC OF IRELAND
ISLE OF MAN
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Single Taxable
Income (EUR)
36,400
balance
Married one income
taxable income (EUR)
45,400
balance
Married two incomes
taxable Income (EUR)
72,800
balance
Tax rate (%)
20
41
Individuals aged over 65 are exempt from tax if their income is less than EUR 20,000.
An income levy applies on income at rates of 2%, 4% or 6% depending on the level of
income.
Companies
Taxable income
All trading income
Non-trading income
Taxable income (GBP)
up to 9,300
from 9,301 - 19,800
from 19,800
Tax rate (%)
0 (tax-free allowance)
10
20
The above thresholds are doubled for those jointly assessed. Increased tax-free
allowance for individuals over 65 being £2,020 per individual, and doubled if jointly
assessed. The Isle of Man has a tax cap of £115,000 for an individual or £230,000 if
jointly assessed.
Companies
Tax rate (%)
12.5
25
VALUE ADDED TAX (VAT)
The standard rate of VAT is 21% (21.5% prior to 1 January 2010). A reduced rate of
13.5% applies to some goods and services including real property and services relating
to property. A zero rating applies to exported goods, fertilisers, books, food, oral
medicine, children’s clothing and footwear.
CAPITAL GAINS TAX (CGT)
The tax rate applicable to capital gains is 25%. Indexation relief is available for the
period of ownership of the asset but only up to 31 December 2002. Non-residents are
subject to Irish capital gains tax on the disposal of land assets.
LOSSES
Individuals
Individual tax losses from trading activities can be offset against other income in the
current year. Losses can be carried forward indefinitely and offset against similar profits
from the same source. Terminal loss relief can be claimed in respect of a loss incurred in
the last 12 months. Such terminal losses can be offset against profits arising in the three
preceding tax years.
Companies
Company tax losses can be offset against other income in the current year, carried back
and offset against income of the previous year or carried forward indefinitely and offset
against similar profits from the same source.
Taxable income
Tax rate (%)
Companies with Banking Business income or Isle of Man
10
land and property income
Companies may opt to pay tax
10
All other companies
0
VALUE ADDED TAX (VAT)
17.5% on majority of sales of goods/services; reduced or zero rate on certain specific
items.
CAPITAL GAINS TAX (CGT)
Not applicable
WEALTH TAXES
Not applicable
TREATY NETWORK
3 countries.
WITHHOLDING TAX (non-residents)
Dividends: 0%
Interest:
0%
Royalties: 0%
Rent:
18% for payments to an individual or 10% for payments to a company
TREATY NETWORK
48 countries.
WITHHOLDING TAX (non-residents)
Dividends: 20%
Interest:
20%
Royalties: 20%
Contact:
Andrew Whitty/John Byrne/Gerard Guilmartin
andrew.whitty@hbc.ie/john.byrne@hbc.ie/gerard.guilmartin@hbc.ie
Horwath Bastow Charleton
Marine House, Clanwilliam Court
Dublin 2
Ireland
Tel: +353 1 676 09 51
www.hbc.ie
18 Europe, Middle East and Africa Tax facts 2010
Contact:
John Cowan
john.cowan@horwath.co.im
Horwath Clark Whitehill LLC
6th floor, Victory House, Prospect Hill,
Douglas, IM1 1EQ
Isle of Man
Tel: +44 1624 627335
Fax: +44 1624 677225
www.horwath.co.im
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ISRAEL
ITALY
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (NIS)
up to 57,240
from 57,241 – 101,640
from 101,641 – 152,640
from 152,641 – 219,000
from 219,001 – 472,080
over 472,080
Tax rate (%)
10
14
23
30
33
45
Individuals are subject to National Social Security and Health tax. Total rate is up to
17.43% for employees and 16.23% for non employees.
Companies
Taxable income
Tax year 2010
Tax rate (%)
25
Taxable income (EUR)
up to 15,000
from 15,001 – 28,000
from 28,001 – 55,000
from 55,001 – 75,000
over 75,000
Progressive tax rate (%)
23
27
38
41
43
Average tax rate (%)
23
25
31
34
34 - 43
Companies
27.5% standard corporate income tax rate for resident companies (IRES). A local tax
(IRAP) at a rate ranging from 3.9% to 4.82% applies on a taxable basis approximately
coinciding with the value of production; employment costs and interest expenses are
generally not deductible.
The tax rate will be reduced up to 18% in 2016.
Non-residents
Non resident companies and individuals: same income tax rates as residents.
VALUE ADDED TAX (VAT)
16% VAT on sales of goods and services; zero tax for certain specific items. Starting 1
January 2011 the tax rate will be reduced to 15.5%.
VALUE ADDED TAX (VAT)
20% standard rate; reduced rates (10% or 4%) apply to certain transactions (e.g. food
products); 0% rate applies on certain transactions (e.g. medical services).
CAPITAL GAINS TAX (CGT)
Individuals
20% on capital gains. On the disposal of shares in which the individual holds more
than 10% of the company's shares the tax rate is 25%.
CAPITAL GAINS TAX (CGT)
Individuals
12.5% tax applies to capital gains on non-qualifying shareholding. Minimum: 11.4% maximum: 21.4% on majority shareholdings. Gains are not taxable when reinvested in
shares of companies involved in the same business, provided that certain conditions are
met.
Companies
A capital gain is part of the taxable income.
LOSSES
Losses from business activities can be set off from all taxable income. Business losses
can be carried over to the following years and will be set off from business activities
only. Capital losses can be set off only from capital gains and in certain conditions from
dividends and interest.
Companies
Residents: 27.5% ordinary rate. Sales qualifying for participation exemption (e.g.
12 months holding period in non black listed resident company and the
like) are 95% tax exempt (effective tax rate 1.38%).
Non-residents: 13.7% effective rate on transfer of shareholdings.
TREATY NETWORK
50 countries.
CORPORATE TAX LOSSES
Tax losses can be carried forward for five years; no carry back is allowed. Losses
incurred in the first three years of activity can be carried forward indefinitely, subject to
certain conditions.
WITHOLDING TAX (non-residents)
Dividends: 25%
Interest:
25%
Royalties: 25%
TREATY NETWORK
81 countries.
Witholding tax can be reduced/exempt under certain circumstances if a treaty is in
force.
WITHOLDING TAX (non-residents)
Dividends: residents and EU residents qualified for Parent/Subsidiary Directive: 0%;
other European Economic Area resident: 1.38%; other foreign residents:
27%
Interest:
residents and EU resident qualifying shareholders: 0%; other non resident:
12.5%; tax haven resident: 27%
Royalties: residents and EU resident qualifying shareholders: 0%; other non resident:
22.5%; tax haven resident: 22.5%
Above withholding tax rates can be reduced on the basis of applicable tax treaties.
Contact:
Isak Roffe
isakr@owp-cpa.co.il
Horwath Owp (Israel) Ovadia Wallenstein Pick & Co
12 Hachilazon St.
Ramat-Gan 52522
Israel
Tel: +972 3 7538300,
Fax: +972 3 7606787
www.crowehorwathinternational.com
20
Europe, Middle East and Africa Tax facts 2010
Contact:
Giusi Lamicela/Gian Paolo Giannini
giusi.lamicela@fisspa.it; gianpaolo.giannini@fisspa.it
Studio Associato Servizi Professionali Integrati
Via San Vito 7
20123 Milano
Italy
Tel: +3902806731
www.fisspa.it
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JORDAN
KENYA
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (JOD)
up to 12,000
over 12,000
Tax rate (%)
7
14
Companies
Sector
Insurance, telecommunication, financial institutes
Banking
Other
Tax rate (%)
24
30
14
VALUE ADDED TAX (VAT)
Jordan operates a sales tax which is similar to VAT.
Sales tax ranges from; exempted goods and services, zero rated goods and services,
goods and services subject to 4% tax, goods and services subject to special tax, goods
and services subject to the general sales tax at the rate of 16%. Essential commodities
attract lower rates than luxury commodities (i.e. alcohol, cigarettes).
Taxable income (KES)
up to 121,968
from 121,969 – 236,880
from 236,881 – 351,792
from 351,793 – 466,704
over 466,704
Companies
Taxable income
Resident Companies
Non-resident companies
EPZ – first ten years
Tax rate (%)
30
37.5
No tax
EPZ – next ten years
20
VALUE ADDED TAX (VAT)
Fixed 16% on goods and services.
CAPITAL GAINS TAX (CGT)
Capital gains realised by shareholders when selling their share in a company are not
subject to income tax (excluding goodwill which is taxable).
Capital gains realised by a company when selling immovable property is subject to
income tax.
CAPITAL GAINS TAX (CGT)
Not applicable
LOSSES
Losses from one source of taxable income can be offset against total income in the
same year. If losses exceed total income they can be carried forward indefinitely.
WITHOLDING TAX
Residents
Dividends: 5%
Interest:
15%
Royalties: 5%
TREATY NETWORK
Over 22 countries
Tax rate (%)
10
15
20
25
30
TREATY NETWORK
Certain countries. Please contact us for further details of your country.
Non-residents
10%
15%
20%
WITHOLDING TAX
Dividends: 0%
Interest:
5%
Royalties: 7%
Contact:
Wael Saif
wael.saif@crowehorwath-me.com
Horwath Consulting Middle East “Jordan”
47 Mecca Street, Al Kharat Building, 4th Floor, Suite 1
P.O. Box 851406 Amman 1185
Jordan
Tel: +962 6 5544180
www.crowehorwath-me.com
22
Europe, Middle East and Africa Tax facts 2010
Contact:
Christopher Msuya
chris.msuya@horwath-tz.com
Horwath Tanzania
13 Zanaki Street,
2nd Floor, Osman Towers
P.O. Box 22731
Dar es Salaam, Tanzania
Tel: +255 22 211 5251-3
Fax: +255 22 213 0519
www.crowehorwathinternational.com
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KUWAIT
LATVIA
INCOME TAX RATES 2010
Individuals
There is no direct personal taxation
INCOME TAX RATES 2010
Individuals
Companies
There is no taxation for local companies.
The following are chargeable to tax at 15%:
the profit of a foreign company operating within or outside Kuwait to the extent that
profits are connected with, or related to its operations within Kuwait
the proportion of the profit of a Kuwaiti joint venture attributable to foreign
corporate partners
the proportion of the profit of a Kuwaiti corporate entity attributable to foreign
corporate shareholders.
VALUE ADDED TAX (VAT)
There is no VAT.
CAPITAL GAINS TAX (CGT)
There is no CGT.
LOSSES
Losses can be carried forward for upto three years.
TREATY NETWORK
Certain countries.
WITHOLDING TAX
Investment companies and banks that manage portfolios and funds are required to
deduct 15% of dividends and profits of foreign companies. A system of retaining 5%
from all contract payments is followed. The retentions are released when tax
assessment is made and a tax clearance certificate is issued.
Contact:
Rabea Saad Al Muhanna
mail@horwathalmuhanna.com
Horwath Al Muhanna & Co
PO Box 26154, Safat
13122 Kuwait
Tel: +965 2457634/9
Fax: +965 2466375
www.horwathalmuhanna.com
24
Europe, Middle East and Africa Tax facts 2010
Taxable income
Most income
Income from capital (e.g. dividends, interest
Tax rate (%)
26
10
Taxable income
All Income
Tax rate (%)
15
VALUE ADDED TAX (VAT)
VAT standard rate is 21%. Reduced rates: 0% and 10%.
CAPITAL GAINS TAX (CGT)
Individuals
E.g. sale of shares, real estate - 15%.
Companies
Capital gains are treated as an ordinary income subject to the corporate income tax.
LOSSES
Latvia allows carry forward of losses for up to eight years. Transfer of losses within a
group of companies is also permitted.
TREATY NETWORK
51 countries.
WITHHOLDING TAX
Dividends: 10% (0% if paid out to EU/EEA shareholder)
Interest (paid to related parties only): 10% (5% if paid by Latvian banks)
Royalties: 15% on copyrights; 5% (others).
Contact:
Dmitrijs Petrovs
petrovs@petrovs.lv
Petrovs & partneri, Law Office
Kr.Valdemara iela 21
Riga, LV-1010
Latvia
Tel: +371 67035381
www.petrovs.lv
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LEBANON
LIECHTENSTEIN
INCOME TAX RATES 2010
Individuals
Non-residents are subject to a flat rate of 7.5%. Residents are subject to progressive tax
on salaries after the deduction of family allowances according to the employee marital
status as follows:
INCOME TAX RATES 2010
Individuals
Assuming a municipal tax surcharge of 200%, the minimum tax rates are as follows: at
least 0.162% and at most 0.8505% for asset tax; at least 3.24% option and at most
17.01% for income tax. Under certain conditions there is the option for foreigners to
pay a lump sum.
Taxable income (LBP)
up to 6,000,000
from 6,000,001 – 15,000,000
Tax rate (%)
2
4
from 15,000,001 – 30,000,000
7
from 30,000,001 – 60,000,000
11
from 60,000,001 – 120,000,000
15
over 120,000,000
20
Companies
The profits of stock companies (Joint Stock companies, Limited Liability companies,
Partnerships limited by shares) are subject to tax at 15%. Rates of taxation on the
profits of commercial, industrial, and non-commercial professions are as follows:
Taxable income (LBP)
up to 9,000,000
from 9,000,001 – 24,000,000
Tax rate (%)
4
7
from 24,000,001 – 54,000,000
12
from 54,000,001 – 104,000,000
16
over 104,000,000
21
Companies
Corporations are subject to a profit tax at a rate between 7.5% and 15% and a capital
tax of 0.2%. Holding and domiciliary companies are subject to a capital tax of 0.1%
but at least CHF 1,000 per year.
VALUE ADDED TAX (VAT)
7.6% calculated on the price of goods and services.
2.4% applies to items such as medicine, newspapers etc.
3.6% on hotel accommodation.
Certain transactions are exempt from VAT, especially charitable, cultural, educational
and religious transactions.
CAPITAL GAINS TAX (CGT)
Individuals
Capital gains are taxed in the same way as ordinary income for individuals.
Companies
Capital gains are taxed in the same way as ordinary profits for corporations.
Offshore Companies are exempt from income tax on their profits and are instead
assessed at a flat annual tax that amounts to LBP 1,000,000 regardless of the amount
of profit.
Profits attained through the sale of real property located in Liechtenstein are subject to
a special tax (real estate profit tax), not to general asset and income or capital and
profit taxes.
Holding Companies are subject to an annual lump sum of 6% on the total value of its
capital and reserve funds if the total does not exceed LBP 50 million. The rate of tax is
reduced to 4% for amounts between LBP 50 million to 80 million and 2% for amounts
exceeding LBP 80 million. This is capped at LBP five million per year.
LOSSES
Losses can be carried forward for five years and be offset against 100% of the income
of the current year.
The following are not subject to tax:
hospitals, orphanages, asylums, consumers’ cooperative companies, trade unions,
agricultural cooperatives of a non-commercial nature, and some kinds of industrial
establishments.
VALUE ADDED TAX (VAT)
A standard rate of 10% applies to the supply of goods and services. There are however
many goods and services that are exempt to VAT.
TREATY NETWORK
3 countries (Austria, Switzerland and Luxembourg).
WITHHOLDING TAX
Dividends: 4%
Interest:
0%
Royalties: 0%
CAPITAL GAINS TAX (CGT)
Revaluations of fixed assets are subject to tax at 10%. Profits from the disposal of fixed
assets are subject to tax at 10%.
LOSSES
Net operating losses can be carried forward for up to three years.
TREATY NETWORK
More than 20 countries.
WITHHOLDING TAX
Dividends: 10%
Interest:
5%
Royalties: 10%
Contact:
Antoun Sawaya
antouns@horwathac.com
Horwath Abou Chakra & Co.
Clemenceau Street, Minkara Bldg. 3rd Floor
P.O.Box 5075-11
Lebanon
Tel: +961(1)364310 Fax: +961(1)364341
www.horwathac.com
26
Europe, Middle East and Africa Tax facts 2010
Contact:
.
Patrick Fuchs
info@horwath.li
Crowe Horwath Treuhand AG
Landstrasse 97
9494 Schaan, Principality of Liechtenstein
Tel: +423 236 19 10
www.horwath.li
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LITHUANIA
LUXEMBOURG
INCOME TAX RATES 2010
Individuals
Taxable income (EUR)
up to 1,633
INCOME TAX RATES 2010
Individuals
Income tax rates are progressive (from 0% up to 38%). The first EUR 11,625 is tax free.
The marginal tax rate applies on income exceeding EUR 39,885. Three tax classes (1,
1a, 2) are available depending upon civil status. A contribution to the unemployment
fund (2.5% of tax) comes in addition. Resident taxpayers pay tax on their worldwide
income, whereas non-resident taxpayers pay tax on specific Luxembourg-sourced
income only (to be analysed on a case by case basis).
over 1,633 (for income received from employer)
Tax rate (%)
0
15
Companies
Taxable income (EUR)
Tax rate (%)
On all income for commercial organisations
15
Over 7,240 for non – profit organisations
15
VALUE ADDED TAX (VAT)
Standard rate 21%
9% on heating for residential premises (until 31st August of 2010) and books (until
31st December 2010)
5% on pharmaceutical (until 31 st December 2010)
CAPITAL GAINS TAX (CGT)
General income tax rate – 15%.
0% if shares were owned for more than 366 days (or three years for holders of less
than 10%).
The first EUR 2,320 of gain is exempt.
LOSSES
Losses, except for the losses incurred on trading in securities and or derivative financial
instruments, may be carried forward for an unlimited period of time.
Losses incurred on trading in securities and/or derivative financial instruments can be
carried forward for no five consecutive tax periods.
TREATY NETWORK
42 countries.
WITHHOLDING TAX (non-residents)
Dividends: individuals – 20%
legal entities – 15% and 0% for holders of 10% and more voting shares
during uninterrupted period of at least 12 months before distribution of
the dividends
Interest:
10% paid for foreign companies only
Royalties:
10% paid for foreign companies only
Companies
The current global corporate tax of 28.59% in Luxembourg–City consists of:
corporate income tax (CIT): 21.84% (includes the 4% Solidarity Surcharge)
municipal business tax (MBT): 6.75% (for Luxembourg–City. This rate varies per
municipality, from 6% up to 12%).
Exemptions are available e.g. in relation with substantial shareholdings, income derived
from IP. Various tax credits and incentives also exist. A Net Wealth Tax (NWT) is also
due on 0.50% of the adjusted net asset value for which certain exemptions are
available. Under certain conditions, profits and losses of Luxembourg group companies
may be pooled (tax consolidation).
Besides the fully taxable regime, various other regimes are available on a case per case
basis for minimising tax burden on revenue flow. These are: the investment company in
risk capital ‘SICAR’, the private wealth management company ‘SPF’, the specialised
investment fund ‘SIF’, the securitisation vehicle ‘SV’. Please also note that the ‘1929
holding companies’ tax regime will disappear after 31 December 2010.
VALUE ADDED TAX (VAT)
Standard rate: 15% parking rate; 12% (unleaded petrol, solid combustibles, fuel, wines,
custody and management of securities). Reduced rate: 6% (gas, electricity, plants).
Super reduced rate: 3% (food, pharmaceutical products, public transport, hotel and
restaurant services, books, water).
CAPITAL GAINS TAX (CGT)
Individuals
These gains may benefit from reduced tax rates and exemptions. An analysis on a case
by case basis is however required.
Companies
Normal global corporate tax rate applies; exemptions (e.g. on sale of substantial
holdings) and roll-over reliefs are available in some cases.
LOSSES
Corporate tax losses can be carried forward indefinitely.
TREATY NETWORK
57 countries.
WITHHOLDING TAX (non-residents)
Dividends: 15%; exemptions foreseen in relation with income derived by companies
from substantial shareholdings
Interest:
individuals: 10% (under certain conditions for resident individuals), 20% if
European Savings Directive applies for non-resident individuals
corporate: Nil
Royalties: abolished
Contact:
.
Jolanta Janušauskiene
auditas@atskaitomybe.lt
UAB "Atskaitomybë ir auditas"
Kalvarijų str. 99a,
LT - 08219 Vilnius
Lithuania
Tel: +370 5 2731250
Fax: +370 5 2195751
www.interbaltic.eu
28
Europe, Middle East and Africa Tax facts 2010
Contact:
Jean–Jacques Soisson
jj.soisson@clerc.lu
Tel: +352 26 38 83 524
Vincent Fasbender
v.fasbender@clerc.lu
Tel: +352 26 38 83 544
CLERC
1 Rue Pletzer
L–8080 Bertrange
Grand Duchy of Luxembourg
www.clerc.lu
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MALTA
MAURITIUS
INCOME TAX RATES 2010
Individuals – residents
INCOME TAX RATES 2010
Individuals
Taxable income (EUR) single/married
couple (separate computation)
up to 8,500
from 8,501 – 14,500
from 14,501 – 19,500
over 19,500
Taxable income (EUR) married
couple (joint computation)
up to 11,900
from 11,901 – 21,200
from 21,201 – 28,700
over 28,700
Tax rate (%)
Taxable income
Tax rate (%)
0
15
25
35
Basic tax rate
15
Individuals – non–residents (married or single)
Taxable income
up to 700
from 701 – 3,100
from 3,101 – 7,800
over 7,800
Tax rate (%)
0
20
30
35
Companies
Taxable income
Al income
Tax rate (%)
35
Company tax is fully credited to shareholders on distribution of profits.
VALUE ADDED TAX (VAT)
18% on majority of goods and services; reduced rate on certain specific items.
CAPITAL GAINS TAX (CGT)
Immovable property
The tax rate applicable to transfers of immovable property is 12% (Final Withholding
Tax) on the transfer value. In certain circumstances, the transferor may opt to be taxed
at standard rates on the gain made on the transfer.
Securities
Standard rates apply in the case of resident persons. Capital gains on transfers of
certain securities derived by non-resident persons are exempt from tax.
From 1 July 2009 the fiscal year moves to a calendar year in Mauritius.
Companies
Business licence
Domestic and Category 1 Global
Category 2 Global
Tax rate (%)
15
0
In addition companies are required to set up a Corporate Social Responsibility (CSR)
fund equal to 2% of prior year book profits from 1 July 2009.
VALUE ADDED TAX (VAT)
Standard rate 15%.
CAPITAL GAINS TAX (CGT)
Gains or profits derived from sale of units or securities are exempt.
TAX LOSSES
Tax losses can be carried forward for up to five years. Annual allowances from capital
expenditure cannot form part of the loss carry forward.
TREATY NETWORK
51 countries.
WITHHOLDING TAX (non-residents)
Interest:
15% (on deposits exceeding Rs. 2,000,000)
Royalties: 10%
Rent:
5%
Payments to contractors and sub-contractors: 0.75%
Payments to providers of services: 3%
LOSSES
Trading losses can be offset against any other income in the current year. Trading losses
can be carried forward indefinitely and offset against any other income.
Capital losses can be offset against capital gains in the current year. Capital losses can
be carried forward indefinitely and offset against future capital gains.
TREATY NETWORK
54 countries.
WITHHOLDING TAX (non-residents)
Dividends: Non-residents - nil
Residents - nil/15% on distributions of untaxed income to resident
individuals
Interest:
Non-residents - nil
Residents - nil
Royalties: Non-residents - nil
Residents - nil
Contact:
Jason Scicluna
tax@horwathmalta.com
Horwath Malta
La Provvida, Karm Zerafa Street, Birkirkara BKR1713
Malta
Tel: +356 21494794/21494792
www.horwathmalta.com
30
Europe, Middle East and Africa Tax facts 2010
Contact:
Ajay O.Sewraz
a.sewraz@sgfinancialservices.com
SG Financial Services Limited
4th Floor, C.A Building, 19, Poudriere Street
Port Louis,
Mauritius
Tel: +230 211 3350
Fax: +230 211-1967/ 213 1373
www.sgfinancialservices.net
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MOROCCO
NETHERLANDS
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (EUR)
up to 2,682
from 2,683 – 4,469
from 4,470 – 5,363
from 5,364 – 7,151
from 7,152 – 16,090
over 16,090
Tax rate (%)
0
10
20
30
34
38
Companies
Taxable income
Basic tax rate
Financial and insurance companies
Tax rate (%)
30
37
VALUE ADDED TAX (VAT)
20% on majority of sales of goods/services; reduced rates on certain specific items.
Taxable income (EUR)
up to 18,218
from 18,219 – 32,738
from 32,739 – 54,776
over 54,776
Progressive tax rate (%)
2.30
10.80
42
52
Social security premiums (%)
31.15 (13.25; 65 and older)
31.15 (13.25; 65 and older)
–
–
The same rates apply to both residents and non-residents.
Individuals – income from substantial interests
In the case of a ‘substantial interest’ in a company (at least 5% of the total issued share
capital) a flat rate of 25% is due on dividends, other income and capital gains arising
from investments. The tax rate applies to residents and non-residents.
Individuals – income from savings and investments
On the balance of assets and debts higher than EUR 20,661 a deemed return on
investment of 4% is taxed at a flat rate of 30% for residents and non-residents.
Companies
CAPITAL GAINS TAX (CGT)
Individuals:
Capital gains are generally taxed at the rate of 20%.
Companies:
Capital gains are taxed in the same way as ordinary profits for corporations.
LOSSES
Carry forward losses:
tax losses (amortisation tax losses excluded) can be carried forward for a period of
four years
amortisation tax losses can be carried forward without time limit.
Taxable income (EUR)
up to 200,000
over 200,000
Tax rate (%)
20
25.5
The same rates apply to both resident and non-resident companies.
VALUE ADDED TAX (VAT)
On supplies of most luxury goods: standard rate of 19%. For specified goods and
services: 6%. Certain exported (and some incoming) goods and services: 0%.
CAPITAL GAINS TAX (CGT)
Individuals
Capital gains are taxed in the same way as ordinary income for individuals.
No carryback of losses is allowed.
TREATY NETWORK
25 countries.
WITHHOLDING TAX (non-residents)
Dividends: 10%
Interest:
10%
Royalties: 10%
Companies
Capital gains are taxed in the same way as ordinary profits for corporations.
LOSSES
Tax losses can be carried back to be offset against income in the prior year. Losses can
be carried forward and offset against future income for nine years.
TREATY NETWORK
87 countries.
WITHHOLDING TAX (non-residents)
Dividends: 15% (unless reduced under relevant treaty or EC directive)
Interest:
0%
Royalties: 0%
Contact:
Adib Bennrahim
benbrahim@horwath.ma
Horwath Maroc Audit
Résidence Kays, Immeuble D appartement 15
Agdal, Rabat
Morocco
Tel: +212 5 37 77 46 70/71
Fax: + 212 5 37 77 46 76
www.horwath.ma
32
Europe, Middle East and Africa Tax facts 2010
Contact:
Hans de Kruijs/Hans Missaar
h.dekruijs@horwathdzdk.nl/h.missaar@horwathdzdk.nl
Horwath de Zeeuw & de Keizer
Jan Leentvaarlaan 50–60
3065 DC Rotterdam
Netherlands
Tel: +31 10 266 15 00
www.horwathdzdk.nl
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NIGERIA
NORWAY
INCOME TAX RATES 2010
Individuals
Taxable income (BWP)
up to 30,000
from 30,001 – 60,000
from 60,001 – 110,000
from 110,001 – 160,000
over 160,000
Page 36
INCOME TAX RATES 2010
Individuals
Tax rate (%)
5
10
15
20
25
Non - resident individuals will only be taxed on unearned (investment income) using
withholding tax.
Withholding tax suffered by the individual can be offset against the tax liability (see
below).
Companies
All companies are taxed at the rate of 30% on profits adjusted for tax purposes
(eliminating depreciation but granting capital allowances). Withholding tax deducted
at source may also be set off against that year’s company tax. Excess withholding tax
paid on dividends in any year cannot be carried forward to set off additional company
tax of any future year.
VALUE ADDED TAX (VAT)
5% on all goods and services except for certain specific items which are exempt or zero
rate.
CAPITAL GAINS TAX (CGT)
Flat rate of 10% on the chargeable gain with some exemptions.
LOSSES
Losses can be carried forward indefinitely but can only be offset against income from
the same source of trade or business.
TREATY NETWORK
Only the United Kingdom is currently active.
WITHHOLDING TAX (non-residents)
Dividends: 10%
Interest:
10%
Royalties: 10%
Taxable income (EUR)
up to 57,050
from 57,051 – 92,713
over 92,713
Tax rate (%)
35.80
44.80
47.80
Increased social security rates for self-employed individuals (11%). Normally, employers
pay an amount equal to 14.1% of payroll without any limits.
Companies
Taxable income
Business income and capital gains
Dividends received
Tax rate (%)
28
3
VALUE ADDED TAX (VAT)
25% on majority of sales of goods/services; reduced rate on certain items.
CAPITAL GAINS TAX (CGT)
Individuals: 28%
Companies:28% Norwegian resident companies are not liable to tax on 97% of gains
from disposal of shares in Norway and from companies established in
real terms and conducting real economic business within EEA
member states. Companies not resident in Norway are usually not
liable to tax on gains from disposal of shares in Norway.
LOSSES
Trading losses are normally deductible from other income and gains in the year
incurred. Losses can be carried forward for an unlimited time.
TREATY NETWORK
77 countries.
WITHHOLDING TAX
Dividends: 0% (companies resident within EEA. EEA tax havens only exempt if
company is established in real terms and conducting real economic
business there)
25% (outside EEA; May be reduced by relevant treaty)
Interest:
0%
Royalties: 0%
Professional fees, technical fees, commissions, management fees agent remuneration
10% for companies and 5% for individuals.
Contact:
Igho Dafinone/Ede Dafinone
igho@dafinone.com/ede@dafinone.com
Horwath Dafinone
16 Wharf Road, Apapa
P.O.Box 2151 Marina,
Lagos
Nigeria
Tel: + 234 1 4600518-9
Fax:+ 234 1 4600618
www.dafinone.com
34 Europe, Middle East and Africa Tax facts 2010
Contact:
Elisabeth Moum
elisabeth.moum@horwathrevisjon.no
Horwath Revisjon AS
Gardermoen Business Centre
2065 Gardermoen Park
Norway
Tel: +47 63 94 38 30
www.horwath.no
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PALESTINE
SULTANATE OF OMAN
INCOME TAX RATES 2010
Individuals
Residents
INCOME TAX RATES 2010
Individuals
No tax on the income of individuals
Companies
Taxable income (RO)
up to 30,000
over 30,000
Page 38
Tax rate (%)
0
12
VALUE ADDED TAX (VAT)
Not applicable
CAPITAL GAINS TAX (CGT)
12% on capital gains wherever earned. Capital gains are added to the total income.
LOSSES
Losses are allowed to be carried forward for a period of five years to set off.
TREATY NETWORK
26 countries.
WITHHOLDING TAX (non-residents)
Dividends: 0%
Interest:
0%
Royalties: 10%
Withholding tax will be charged at a rate of 10% on the following categories of income
accruing in Oman.
1. Royalties.
2. Consideration for research and development.
3. Consideration for the use of or right to use computer software.
4. Management fees.
Taxable income (USD)
up to 10,000
from 10,001– 20,000
over 20,000
Tax rate (%)
5
10
15
Non residents are taxed at 10%.
Companies
Taxable income
All income
Tax rate (%)
15
VALUE ADDED TAX (VAT)
VAT is 14.5 % on all goods and services provided in Palestine except for hotel
accommodation for foreigners which is zero. Some International organisations in the
course of providing assistance to Palestinians are authorised to buy at a zero
percentage.
CAPITAL GAINS TAX (CGT)
Capital gains arising from the sale of land and/or properties are exempt provided that
such activity is not part of that person’s work. Also capital gains arising from the sale of
securities for banks and financial institutions’ portfolios are exempt. All other capital
gains are taxed at the corporate and individual tax rates.
LOSSES
Losses can be carried forward for up to five years in certain circumstances.
TREATY NETWORK
0 countries.
WITHHOLDING TAX (non-residents)
Dividends: dividends distributed by a resident company in Palestine, on whose taxable
income tax has been paid are exempt
Interest:
same as corporate and individual rates
Royalties: same as corporate and individual rates.
Note: The income tax law is currently under review, therefore the above figures may
change later in 2010.
Contact:
Davis Kallukaran
davis@horwathoman.com, makmct@omantel.net.om
Horwath Mak Ghazali LLC
P.O. Box. 971, P.C. 131, Al Hamriya
Sultanate Of Oman
Tel: +968 24813983/ 87/ 89
Fax: +968 24813915
www.horwathoman.com
36
Europe, Middle East and Africa Tax facts 2010
Contact:
Abla Sameeh Maayah
abla@maayah.com
Maayah & Co Accounting Firm
Al-Salam Street/ PO Box 442
Ramallah
Palestine
Tel: +972 2 2955294
Fax: +972 2 2959513
www.crowehorwathinternational.com
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POLAND
PORTUGAL
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (PLN)
up to 85,528
over 85,528
Tax rate (%)
18 minus the tax reduction amount of PLN 556.02
32
The above tax rates apply to both residents (for worldwide income) and non-residents (for
income earned in Poland). Some exceptions are provided for e.g. income of non-residents
being management board members appointed under resolution of shareholders are taxed at
20% flat rate (upon a non-resident’s request, income may be taxed at the progressive tax
rates). Taxpayers who earn non-agricultural business activity income can choose between
taxation at the flat rate of 19% or taxation on the basis of the general rules.
Companies
Taxable income
All income
Tax rate (%)
19
VALUE ADDED TAX (VAT)
22% is for most goods and services.
7% is for sale of new flats, certain foodstuffs, hotel services.
3% is applied to most foodstuffs.
0% to export and intra–community supply of goods.
VAT exempted, e.g. supply of buildings, structures and parts thereof (with exceptions),
educational services, health care services, selected services of financial brokerage.
CAPITAL GAINS TAX (CGT)
There is generally one flat tax rate of 19% on capital income for individuals subject to personal
income tax (PIT) (with some minor exceptions). Corporations subject to CIT add capital gains
to their regular profits and pay regular CIT at the rate of 19%.
LOSSES
Both individuals and companies may carry forward losses to offset profits for five consecutive
years. In each of these years, the offset may not exceed 50% of each year’s loss. Losses cannot
be carried back.
TREATY NETWORK
Treaties signed with 84 countries (80 in force and effect).
WITHHOLDING TAX (non–residents)
For income earned in Poland by taxpayers who do not have a registered office or place of
management in Poland.
Dividends: 19%
Interest:
20%
Royalties:
20%
Performance of e.g. advisory, accounting, legal services: 20%
Provisions of Double Tax Treaties may decrease the above rates or exempt from taxation.
Interest and Royalty Directive (2003/49/EC)
from 1 July 2009 to 30 June 2013 – Poland may impose witholding tax on interest and
royalties at the maximum rate of 5%
from 1 July 2013 – income derived from interest and royalties will be witholding tax exempt
The preferential rules of taxation apply, provided that (i) the minimum shareholding amounts
to 25% and (ii) the shares have been held for an uninterrupted period of at least two years.
Parent-Subsidiary Directive (90/435/EEC)
Dividends as well as other income derived from a share in profits of legal persons is CIT
exempt, provided that (i) a shareholder, an entity from EEA, has held no less than 10% of
shares of the Polish company for an uninterrupted period of two years. In the case of
Switzerland the minimum shareholding amounts to 25%.
Contact:
Wojciech Sztuba
wojciech.sztuba@tpa–horwath.pl
TPA Horwath Sztuba Kaczmarek Sp. z o.o.
ul. Zydowska 1
61–761 Poznan
Poland
Tel: +48 61 851 38 60
www.tpa-horwath.pl
38
Europe, Middle East and Africa Tax facts 2010
Taxable income (EUR)
up to 4,793
from 4,794 to 7,250
from 7,251 to 17,979
from 17,980 to 41,349
from 41,350 to 59,926
from 59,927 to 64,623
over 64,623
Column A - normal rate (%)
10.5
13
23.5
34
36.5
40
42
Column B - medium rate (%)
10.5000
11.3471
18.5996
27.3039
30.1546
30.8702
–
The amount of taxable income if higher than EUR 4,793 is divided into two parts: one equal to
the limit of the highest bracket comprised therein, to which the rate of column B corresponding
to such bracket applies; the other equal to the exceeding fraction to which the rate of the
column A corresponding to the next highest bracket applies. The income of a married couple or
people living together as a married couple for at least two years, is divided by two for purposes
of the tax tables application.
Companies
From 1 January 2009, the standard income tax rates for resident companies and Permanent.
Establishments whose main activity is of a commercial, industrial or agricultural nature are as
follows:
for income up to EUR 12,500, a rate of 12.5% applies
for income above EUR 12,500, a rate of 25% applies.
A 1.5% rate is added to the federal rates resulting in combined effective rates of 14% and 26.5%
respectively.
VALUE ADDED TAX (VAT)
20% on majority of sales of goods/services, reduced (12% and 5%) or zero rate on certain
specific items.
CAPITAL GAINS TAX (CGT)
Individuals
Not liable to capital gains tax on gains derived from the transfer of:
shares owned by the respective owner for more than 12 months
bonds and debentures.
Capital gains arising from the disposal of shares/quotas are taxed at a special flat rate of 10% if
obtained by residents and at a 25% flat rate if obtained by non-residents.
Companies
50% of the capital gains on the disposal of fixed assets and the disposal of share capital (shares
or quotas) are tax exempt if the reinvestment of the corresponding sales values occurs in the
year prior to the disposal, in the year of the disposal or in the two following years.
LOSSES
Both individual (carrying out a commercial or industrial activity as self-employed) and company
tax losses can generally be carried forward against the income obtained in the following six
years.
TREATY NETWORK
53 countries.
WITHHOLDING TAX
Dividends: 20%
Interest:
20%
Royalties:
20% non residents/15% residents (this withholding tax has the character of an
advanced payment)/5% EU Members (Council Directive 2003/49/CE, of 3 June
2003).
Note: This data was provisional and not approved by the Portuguese Parliament at the time of
printing.
Contact :
José Carlos de Carvalho Velez
josevelez@horwath-jv.com
Horwath JV – Consultoria Fiscal e de Gestão, Lda.
Edifício Scala – Rua de Vilar, n.º 235, 2º andar
4050 – 636 Porto
Portugal
Tel: +351 226 076 270
Fax: +351 226 076 279
www.crowehorwathinternational.com
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QATAR
ROMANIA
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income
All income
Tax rate (%)
5-7
Companies
Taxable income (QAR)
From 100,000
VALUE ADDED TAX (VAT)
Not applicable
CAPITAL GAINS TAX (CGT)
Not applicable
LOSSES
Losses can be carried forward for up to three years.
TREATY NETWORK
40 countries.
WITHHOLDING TAX
Dividends: 7%
Interest:
7%
Royalties: 7%
Tax rate (%)
10
Taxable income
Tax rate (%)
All income
16
Companies
Taxable income
All income
Tax rate (%)
16
MINIMUM CORPORATE TAX
Starting from 1 May 2009, legal entities are liable to pay a minimum amount of corporate
income tax of between RON 2,200 and RON 43,000, depending on the amount of total
annual revenues derived in the previous year.
Total annual revenues (RON)
Up to 52,000
52,001 – 215,000
215,001 – 430,000
430,001 – 4,300,000
4,300,001 – 21,500,000
21,500,001 – 129,000,000
Over 129,000,000
Annual minimum tax (RON)
2,200
4,300
6,500
8,600
11,000
22,000
43,000
VALUE ADDED TAX (VAT)
The standard VAT rate is 19%. A reduced rate of 9% or zero rate is applied on specific goods
and services. A VAT rate of 5% has been introduced starting from January 2009, applicable to
the supply of social housing (including related land).
CAPITAL GAINS TAX (CGT)
Individuals
Gains from selling social parts in a Limited Liability Company (LLC): 16% of income tax.
Disposal of real estate: progressive rate of up to 2% or 3% depending on the ownership
period.
Companies
Capital gains are subject to 16% tax (inclusive of capital gains derived from the disposal of
investments in corporations).
LOSSES
Losses may be carried forward for a period of five years. Tax losses incurred starting from 2009
may be carried forward for the following seven years. The carry back of losses is not permitted.
No provisions regarding groups.
TREATY NETWORK
80 countries.
WITHHOLDING TAX (non-residents)
Dividends: 0% provided for EU/EFTA qualifying shareholders; 10% (unless reduced/exempt
under EC Directive or the relevant treaty) provided for EU/EFTA member States;
16% other non-residents
Interest: 10% applies to interest paid to an EU or EFTA resident company that holds at least
25% of the shares in the Romanian company for a continuous period of two years.
16% applies to interest paid to other non-residents.
Royalties: 10% applies to royalties paid to an EU or EFTA resident company that holds at least
25% of the shares in the Romanian company for a continuous period of two years.
16% applies to royalties paid to other non-residents.
Contact:
Al Chaa Adib
chaudit@qatar.net.qa
Dawoud&Co. Horwath Qatar
17048 Doha
Qatar
Tel: +974 4422211
Fax +974 447978
www.crowehorwathinternational.com
40
Europe, Middle East and Africa Tax facts 2010
Contact:
Jan Glas,
jan.glas@tpa–horwath.ro
TPA Horwath Quintus,
46, Grigore Cobalcescu
Str. Et. 2, Apt 5, Sector 1,
Bucharest Romania
Tel: +40 21 310 06 69
www.tpa-horwath.ro
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RUSSIA
SAUDI ARABIA
INCOME TAX RATES 2010
Individuals
Residents
13% on all income except:
9% on dividends
35% on some types of income over a certain amount (interests, gambling income etc.)
INCOME TAX RATES 2010
Non-residents
30%, except dividends which are taxed at 15%.
Companies
Residents
20% on all income except:
15%/9%/0% on interest income earned from government and municipal equity securities,
some types of bonds depending on certain conditions
0%/9% on dividends (for more information see section on withholding tax).
Non-residents
20% on all income except:
• 10% on income gained from use, keeping or lease of ships, aircrafts, liners, trailers and other
moveable transportation
• 15% on dividends (for more information see section on withholding tax).
VALUE ADDED TAX (VAT)
Standard rate 18%.
10% on food products, goods for children, books and medical products.
0% applies to sales of exported goods, as well as work and services directly connected with
production and sale of such goods, work (services) connected with transportation of goods to
the customs territory of the Russian Federation, services in transportation of passengers and
baggage.
CAPITAL GAINS TAX (CGT)
In the Russian Federation, capital gains in the form of dividends, interest on liabilities, interest
on securities, sale of assets and other types of income are taxed at the ordinary income tax
rates.
LOSSES
Entities that incurred losses in previous tax periods are entitled to reduce the tax base of the
current tax period by the complete amount of loss or part of that amount.
Individuals
There are no direct personal taxation.
Companies
Taxable income
Saudi and Gulf resident companies
Foreign companies and non-resident companies
Gas sector
Oil and hydrocarbon sector
Tax rate (%)
2.5
20
30
85
VALUE ADDED TAX (VAT)
Not applicable
CAPITAL GAINS TAX (CGT)
20%
LOSSES
A taxpayer is entitled to carry forward adjusted operating losses indefinitely provided
that the maximum deduction in each tax year does not exceed 25% of the annual
profit per the tax return.
TREATY NETWORK
11 countries.
WITHHOLDING TAX
Any resident, whether a taxpayer or a non-taxpayer, any permanently established nonresident enterprises and any person who pays any amounts to a non-resident from an
in-Kingdom source is required to withhold tax from the amount paid at the following
rates:
Rent
Royalty or Return
Management
Payments for airline tickets or air or sea or frieght
Payments for international telephone communications
Any other payments specified by the By-Law
5%
15%
20%
5%
5%
No more than 15%
TREATY NETWORK
74 countries.
WITHHOLDING TAX
Dividends: 15% on dividends paid to foreign entities
0% on dividends paid to Russian entities if more than 50% of shares held for at
least a year and maximum capital RUB$ 500m
9% on dividends paid to Russian entities otherwise
Interest: 15%, 9%, 0% on interest income gained from government and municipal equity
securities, some types of bonds depending on certain conditions
20% – on all other types of income earned from debt liabilities of Russian entities
Royalties: 20 % – are taxed at the source of payment when a taxpayer pays interest to foreign
entities.
Rates above may be reduced by double tax treaties.
Contact:
Dmitry Telipenko
TelipenkoDM@rbsys.ru
Audit-consulting group "Business Systems Development" (RBS)
5/3 Sushchevsky Val
Moscow, 127018
Russia
Tel: +7(495) 967-68-38
www.rbsys.ru
42
Europe, Middle East and Africa Tax facts 2010
Contact:
Abdullah M. AlAzem
aalazem@horwath.com.sa
AlAzem & AlSudary certifide public accountants
AlOlya Street P.O.BOX: 10504
Riyadh : 11443
Saudi Arabia
Tel: +966 1 2175000
Fax: +966 1 2176000
www.crowehorwathinternational.com
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SLOVAKIA
SLOVENIA
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income
All income
Tax rate (%)
19
Companies
Taxable income
All income
Tax rate (%)
19
Taxable income (EUR)
up to 7,528.99
from 7,529 to 15,057.96
over 15,057.96
Tax rate %
16
27
41
General tax relief (between EUR 3,100.17 and EUR 5,194.99).
Companies
VALUE ADDED TAX (VAT)
Standard rate 19%. A reduced rate of 10% is imposed on certain specific items (e.g.
certain medication, medical aids, books, brochures etc.).
CAPITAL GAINS TAX (CGT)
Capital gains of resident individuals and companies are subject to the standard flat tax
rate of 19%.
The sale of real estate by individuals is tax free after five years (two years if the real
estate is the principal residence of the taxpayer).
LOSSES
Losses may be carried forward for a maximum of seven taxable periods (for five taxable
periods in case of losses occurred before 2010). Losses in the case of a merger or a
de-merger may be carried forward by the legal successor (merger/de-merger may not
be made for tax avoidance purposes).
TREATY NETWORK
61 countries.
WITHHOLDING TAX
Dividends:
0%
Interest:
19% (unless exempt or reduced under relevant treaty), EU Royalties
and Interest Directive may apply*
Royalties:
19% (unless exempt or reduced under relevant treaty), EU Royalties
and Interest Directive may apply*
*Applicable to groups of companies with a minimum 25% interest held for at least 24
months
Contact:
Peter Danovsky
peter.danovsky@tpa-horwath.sk
TPA Horwath TAX, k.s.
Pribinova 25/4195
811 09 Bratislava
Slovakia
Tel: +421 2 2067 8911
Fax: +421 2 2067 8913
www.tpa-horwath.sk
44
Europe, Middle East and Africa Tax facts 2010
Taxable income
Year 2007
Year 2008
Year 2009
Year 2010
Tax rate %
23
22
21
20
VALUE ADDED TAX (VAT)
20%
8.5% (food, drugs, books, culture events etc.)
0% (exports)
CAPITAL GAINS TAX (CGT)
20% from 0 to 5 years of shareholding
15% from 5 to 10 years of shareholding
10% from 10 to 15 years of shareholding
5% from 15 to 20 years of shareholding
0% after 20 years of shareholding
LOSSES
Losses can reduce the tax base, without limitation.
TREATY NETWORK
44 countries.
WITHHOLDING TAX
Dividends: 15%*
Interest:
15%*
Royalties: 15%*
*Or per applicable DTA and applying the EU Parent-Subsidiary Directive for group
purposes (participation at least 10% and holding period 24 months).
Contact:
Dr. Michael Knaus
Michael.knaus@tpa-horwath.si
TPA Horwath d.o.o.
Leskoškova cesta 2
1000 Ljubljana
Slovenia
Tel: +386 1 520 86 60
Fax: +386 1 520 86 69
www.tpa-horwath.si
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SOUTH AFRICA
SPAIN
INCOME TAX RATES 2010
Individuals (residents and non-residents)
INCOME TAX RATES 2010
Individuals
Taxable income (ZAR)
up to 140,000
from 140,001 – 221,000
from 221,001 – 305,000
from 305,001 – 431,000
from 431,001 – 552,000
over 552,000
Tax rate (%)
18
25
30
35
38
40
Basic Tax Rebate – ZAR 10,260 (ZAR 15,935 if over age 65).
Taxable income (EUR)
up to 17,707.20
Non-resident – 33% flat rate with no tax on dividends declared.
VALUE ADDED TAX (VAT)
14% on the supply of virtually all goods and services. Very few exemptions (e.g.
personal use assets). Exports and basic foods vatable at zero rate.
CAPITAL GAINS TAX (CGT) (only taxable in respect of periods after 1 October
2001)
Individuals
25% of taxable capital gains added to other taxable income.
Companies and most trusts
50% of taxable capital gains added to other taxable income.
Non-residents
Only liable in respect of disposals of real estate and business assets.
LOSSES
Deductible off taxable income and may be carried forward (not back) indefinitely for
individuals and companies (if such companies do not interrupt their trading activities).
TREATY NETWORK
Currently 70 countries (approximately 22 more being negotiated).
WITHHOLDING TAX (if no treaty applicable)
Dividends: 0% (10% to be introduced in 2010)
Interest:
0%
Royalties: 12%
Remuneration of non-resident entertainers and sportspersons: 15%
Capital Gains on disposal of Real Estate by non-residents: 5-10% of gross proceeds
Contact:
Kent Karro
kent.karro@horwath.co.za
Horwath Zeller Karro
P O Box 43, Cape Town, 8000
South Africa
Tel: +27 21 4817000
www.horwath.co.za
46 Europe, Middle East and Africa Tax facts 2010
from 33,007.21 – 53,407.20
37
over 53,407.20
43
Companies
Small-size companies tax regime1
Net profit (EUR)
Tax rate (%)
up to 120,202.41
25
over 120,202.41
30
Most trusts (resident and non-resident)
40% flat rate of tax.
Companies
Resident – 28% flat rate plus further 10% company secondary tax (to fall away in late
2010 in favour of a 10% withholding tax) on the amount of dividends declared.
from 17,707.21 – 33,007.20
Tax rate (%)
24
28
General tax regime
Tax rate (%)
30
1
Less than EUR 8 million of annual turnover.
Non-residents
Permanent establishments: tax paid at 30% on net profit.
Non-permanent establishments: General tax rate 24% both for individuals and
companies.
VALUE ADDED TAX (VAT)
16% (increased to 18% from 1 July 2010) on majority of sales of goods/services
reduced - 7% (increased to 8% from 1 July 2010), super reduced - 4% or zero rate on
certain specific items.
CAPITAL GAINS TAX (CGT)
Individuals
tax paid at 19% rate on capital gains for non-residents.
tax paid at 21% rate on capital gains for residents (19% for the first EUR 6,000).
special rules of exemption for goods acquired before the Tax Year 1996.
Companies
tax paid at company tax rate; 12% tax relief available in case of re-investment on
tangible, intangible or financial assets within three years when some conditions are
met.
tax paid at 19% rate on capital gains for non-residents.
LOSSES
Both individual and company tax losses can be offset against similar profits from the
same source in the current year, or carried forward and offset against income of the
following year (up to four years for individuals and up to 15 years for companies).
TREATY NETWORK
70 countries.
WITHHOLDING TAX (non-residents)
Dividends: 19% (residents), 0% (EU residents) and 19% (non-EU residents)
Interest:
19% (residents), 0% (EU residents) and 19% (non-EU residents)
Royalties: 19% (residents), 10% (EU residents) and 24% (non-EU residents)
Contact:
Jesús Romero
jesus.romero@crowehorwath.es
Crowe Horwath Legal y Tributario
Avda. Diagonal, 429 5ª Planta
08036 - Barcelona
Spain
Tel: +34 93 244 89 00
www.crowehorwath.es
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SWEDEN
SWITZERLAND
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Residents: 0 - 40% depending on location (26 cantons with different tax brackets).
For foreigners, lump sum taxation is available under certain circumstances.
Taxable income (EUR)
up to 1,818
from 1,819 – 37,586
from 37,587 – 53,808
over 53,808
Tax rate (%)
0
31 – 34
51 – 54
56 – 58
Companies
Taxable income
All income
Tax rate (%)
26.3
VALUE ADDED TAX (VAT)
The standard VAT rate is 25% but reduced to 12% on e.g. foods and hotel rooms, and
6% on e.g. newspapers, books, magazines, transfers of copyrights and personal
transportation.
CAPITAL GAINS TAX (CGT)
Individuals
A 30% flat tax rate is levied on capital gains and 22% on personal dwellings. Capital
gains on personal belongings are tax-free up to a limit of EUR 5,050.
Companies
The tax rate on capital gains is 26.3%. However, capital gains are tax-free on unquoted
shares and if quoted and held for at least 12 months, the shareholding represents at
least 10% of the voting power or the shares are held for sound business reasons.
LOSSES
Losses are normally fully deductible in companies except for losses on shares if capital
gains on the particular shares would have been tax-free (see above). Losses on portfolio
investment shares/certain real estate may only be offset against capital gains on such
assets or carried forward indefinitely to be set off against such capital gains.
Companies
9 - 25% depending on location (26 cantons with different tax brackets) and tax
status (e.g. administration company, holding company).
VALUE ADDED TAX (VAT)
7.6% on majority of goods/services; 2.4% on specific items; 3.6% on hotel
accommodation (beginning 2011 8%, 2.5% and 3.8% respectively).
CAPITAL GAINS TAX (CGT)
Individuals
Generally no CGT, but real estate gains tax. The tax rate is usually progressive with
respect to the gain realised and at reducing rates with respect to the holding period
(26 cantons with different tax brackets).
Companies
Generally no taxation on sale of subsidiaries.
LOSSES
Losses can be carried forward for seven years; no loss carryback.
TREATY NETWORK
79 countries.
WITHHOLDING TAX (non-residents)
Dividends: 35%
Interest:
0% (banks 35%)
Royalties: 0%
TREATY NETWORK
79 countries (complete treaties).
WITHHOLDING TAX
Dividends: 30% but usually reduced to 0% on dividends from subsidiaries
Interest:
0%
Royalties: 0% but often taxed by direct assessment
Contact:
Lars Engström
lars.engstrom@horwath.se
Tönnerviks Horwath Revision
S Vallviksvägen 12
352 51 Växjö
Sweden
Tel: +46 470 795 600
www.horwath.se
48
Europe, Middle East and Africa Tax facts 2010
Contact:
Olaf Ott
olaf.ott@curator.ch
Curator & Horwath AG
Brandschenkestrasse 60
8027 Zürich
Switzerland
Tel: +41 44 208 23 23
www.curator.ch
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TANZANIA
TUNISIA
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
Taxable income (TZS)
up to 100,000
Tax rate (%)
0
Taxable income (TND)
Rate (%)
Real rate (%)
up to 1,500
0
0
from 100,001 to 360,000
15
from 360,001 to 540,000
20
from 1,500 – 5,000
from 5,001 – 10,000
15
20
10.5
15.25
from 540,001 to 720,000
25
30
from 10,001 – 20,000
25
20.12
from 20,001 – 50,000
over 50,000
30
35
26.05
over 720,000
–
Companies
Both resident and non-resident corporations are taxed at a flat rate of 30%. A newly
listed company with Dar es Salaam Stock Exchange with at least 35% of its equity
issued to the public is taxed at a concessionary rate of 25% for three consecutive years
from the date of listing. Repatriated income of a resident branch of a non-resident
person is taxed at 10%.
The above tax rates apply to all income (including capital gains realised in the course of
a business, speculative gains etc.), except dividend income and most savings income.
The same rates apply to both residents and non-residents.
VALUE ADDED TAX (VAT)
The standard rate of VAT is 18%. A zero rating applies to export of goods and certain
services, agriculture implements, fertilizers, fishing gears and human medicines.
Companies
The corporation tax is payable at the general rate of 30% based on the income of the
financial year. Financial, banking and gas companies support the rate of 35% and for
agriculture the rate is 10%. The same rates apply to both residents and non-residents
and benefits from exportation activities paying no income tax.
CAPITAL GAINS TAX (CGT)
Disposal of investment assets
Individuals
Companies
Resident (%)
10
30
Non-resident (%)
20
30
LOSSES
In principle losses can be carried forward indefinitely and offset against similar profits
from the same source. Corporations with unrelieved losses for three consecutive years
of income resulting from tax incentives shall be taxed at a rate of 0.3% of the turnover
of the third year effectively from July 2009.
TREATY NETWORK
9 countries.
WITHHOLDING TAX
Dividends:
to company controlling 25% of shares or more
from Dar es Salaam Stock Exchange
– listed company
from other companies
Interest:
Royalties:
Contact:
Christopher Msuya
chris.msuya@horwath-tz.com
Horwath Tanzania
13 Zanaki Street,
2nd Floor, Osman Towers
P.O. Box 22731
Dar es salaam, Tanzania
Tel: +255 22 211 5251-3
Fax: +255 22 213 0519
www.crowehorwathinternational.com
50
Europe, Middle East and Africa Tax facts 2010
Residents
Non-residents
0%
10%
5%
10%
10%
15%
5%
10%
10%
15%
VALUE ADDED TAX (VAT)
The standard rate of VAT is 18%. A reduced rate of 12, 10 and 6% applies to some
goods and services and some others (agriculture, culture, petroleum services) are
exempt. A zero rating is applied to exported goods and services.
CAPITAL GAINS TAX (CGT)
For the companies there is no separate CGT. Capital gains are included in the taxable
base of the income of the resident. For individuals, the capital gains are taxable at rates
5% or 10% for the residents and 2.5% for non-residents.
LOSSES
May be carried forward and deducted from future taxable income for a limited period
of four years. The part of losses representing amortisation can be forward and deducted
for a unlimited period. Each member of a corporate group is treated as a seperate
entity.
TREATY NETWORK
49 countries.
WITHHOLDING TAX
Residents:
Dividends: exempt
Interest:
20%
Royalties: 15%
Non-residents:
exempt
2.5%
15%
Contact:
Noureddine Ben Arbia
acf@horwath.com.tn
Horwath ACF
Immeuble PERMETAL, 3ème Etage
35, Rue Hédi Karray, Centre Urbain Nord
1082 Tunis Tunisie
Tel: +216 71 236 000
Fax: +216 71 238 800
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TURKEY
UNITED ARAB EMIRATES
INCOME TAX RATES 2010
Individuals
INCOME TAX RATES 2010
Individuals
No direct personal taxation.
Lower bracket (TRY)
Upper bracket (TRY)
Tax on lower (TRY)
Tax rate (%)
0
8,800
22,000
50,000
8,800
22,000
50,000
0
1,320
3,960
11,520
15
20
27
35
–
Companies
Taxable income
All income
Tax rate (%)
20
VALUE ADDED TAX (VAT)
The standard tax rate is 18%; 8% and 1% rate also applied on specific goods and
services.
CAPITAL GAINS TAXES (CGT)
Individuals
Individuals are not taxed on gains arising from the sale of joint stock companies. Sales
of shares in a limited company must be declared and are subject to progressive income
tax. On the sale of real estate, if assets are held for more than four years the capital gain
is exempt from tax. Capital gains arising from the sale of real estate which is held for
less than four years is subject to progressive income tax with the first TRY 7,700 exempt
in 2010.
Corporate
25% of the capital gains arising from the sale of participation shares and real estate
which were held as an asset for more than two years are subject to corporate tax at the
rate of 20%. (75% of capital gains are exempt from corporate tax).
LOSSES
Losses may be offset against other income and capital gains for the same accounting
period for companies. Losses may be carried forward for five years.
Companies
In practice, only the following are required to pay tax:
oil companies – 55% on their taxable income earned in Dubai and 50% in other
Emirates in addition to royalties on production
foreign Banks – 20% of their taxable income as per the audited financial statements.
CUSTOMS DUTY (Federal Customs Authority)
10% on luxury goods, alcohol at 50% and cigarettes at 100%.
4% on the cost, insurance and freight (C.I.F.) of goods imported, however, in practice,
exemptions are made for a wide range of goods such as food products and medicines.
In cases where customs duties are charged, it is generally restricted to 1%.
VALUE ADDED TAX (VAT)
The introduction of a VAT system in the United Arab Emirates (UAE) looks set to go
ahead but later than planned.
As per the local media, replacing import tariffs with VAT will involve the creation of a
huge infrastructure and may not be possible unless all six member states of the Gulf
Cooperation Council (GCC) adopt the system simultaneously.
CAPITAL GAINS TAX (CGT)
Not applicable
LOSSES
Not applicable
TREATY NETWORK
47 countries.
WITHHOLDING TAX
Not applicable
TREATY NETWORK
71 countries.
WITHHOLDING TAX
Dividends: 15%
Interest:
15%
Royalties: 20%
Contact:
Alpaslan Görünmez
alpaslan@taspinar.com.tr
Taşpınar Yeminli Mali Müşavirlik A.Ş.
Yıldız Posta Caddesi Dedeman
ş Hanı No: 48/1 Gayrettepe
Istanbul
Turkey
Tel: +90 0 212 267 10 01
www.horwathturkey.com
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PROPERTY TAXES
There are no property taxes in the United Arab Emirates but there is a ‘transfer fee’ of
2% on the transfer value of the property.
OTHER LOCAL TAXES
Municipal taxes are levied on hotels and dining outlets and the rate and application
methods vary from Emirate to Emirate.
Contact:
Carmen Roman
carmen@horwathmak.com
Horwath Mak
P O Box 6747, Dubai
United Arab Emirates
Tel: +971 4 2283008
Fax: +971 4 2283007
www.horwathmak.com
Europe, Middle East and Africa Tax facts 2010
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UNITED KINGDOM
INCOME TAX RATES 2010
Individuals
Taxable income (GBP)
Tax rate (%)
up to 6,475
from 6,476 – 43,875
over 43,876 – 150,000
over 150,000
0 (tax free allowance)
20
40
50 (from 6 April 2010)
The tax free allowance may be higher for those over 65 and may be lower or nonexistent for those earning over GBP 100,000. There are separate rates of taxation for
dividend income.
Companies
Taxable income (GBP)
up to 300,000
from 300,001 – 1,500,000
over 1,500,000
Tax rate (%)
21
29.75
28
The number of associated companies lowers the band limits of corporation tax.
VALUE ADDED TAX (VAT)
17.5% on majority of sales of goods and services; reduced or zero rate on certain
specific items.
CAPITAL GAINS TAX (CGT)
Individuals
18% on gains in excess of GBP 10,100 per tax year.
Companies
Tax paid at company tax rate; indexation based on retail price inflation is available.
LOSSES
Losses can be set against total income in the year or carried back against income in the
previous year. Losses can be carried forward to set against similar profits from the same
source.
TREATY NETWORK
119 countries.
WITHHOLDING TAX (non-residents)
Dividends: 0%
Interest:
20%
Royalties: 20%
Contact:
David Mellor
david.mellor@horwath.co.uk
Horwath Clark Whitehill LLP
St Bride’s House, 10 Salisbury Square
London, EC4Y 8EH
United Kingdom
Tel: +44 207 842 7100
www.horwathcw.com
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