OECD TAX DATABASE EXPLANATORY ANNEX (Document updated May 2013) 1 Table of contents PART I. TAXATION OF WAGE INCOME 6 AUSTRALIA AUSTRIA ITALY MEXICO 6 6 7 7 Part I, Table 1 8 I.1. AUSTRIA I.1. BELGIUM I.1. CHILE I.1. FINLAND I.1. GERMANY I.1. ITALY I.1. LUXEMBOURG I.1. MEXICO I.1. NETHERLANDS I.1. NORWAY I.1. POLAND I.1. SLOVAK REPUBLIC I.1. SLOVENIA I.1. SPAIN I.1. SWITZERLAND I.1. UNITED KINGDOM I.1. UNITED STATES 8 8 9 10 11 14 16 17 19 19 19 20 21 22 23 23 24 Part I, Table 2 24 I.2. BELGIUM I.2. CANADA I.2. DENMARK I.2. FINLAND I.2. ICELAND I.2. ITALY I.2. KOREA I.2. NORWAY I.2. PORTUGAL I.2. SPAIN I.2. SWEDEN I.2. SWITZERLAND I.2. UNITED STATES 24 25 30 30 30 31 33 33 33 33 34 34 34 Part I, Table 3 36 I.3. CANADA I.3. SPAIN I.3. SWITZERLAND 36 36 36 PART II. TAXATION OF CORPORATE AND CAPITAL INCOME 37 Part II, Table 1 37 2 II.1. BELGIUM II.1. CANADA II.1. CHILE II.1. FRANCE II.1. GERMANY II.1. GREECE II.1. HUNGARY II.1. ISRAEL II.1. ITALY II.1. LUXEMBOURG II.1. MEXICO II.1. NETHERLANDS II.1. NORWAY II.1. POLAND II.1. SWITZERLAND II.1. UNITED STATES 37 38 38 38 39 39 42 42 43 48 49 49 49 50 50 50 Part II, Table 2 51 II.2. AUSTRALIA II.2. BELGIUM II.2. CANADA II.2. CHILE II.2. CZECH REPUBLIC II.2. HUNGARY II.2. ISRAEL II.2. ITALY II.2. MEXICO II.2. NETHERLANDS II.2. NORWAY II.2. PORTUGAL II.2. SLOVAK REPUBLIC II.2. SPAIN II.2. UNITED KINGDOM II.2. UNITED STATES 51 51 54 54 55 55 55 56 56 57 57 57 58 58 59 60 Part II, Table 3 61 II.3. CANADA II.3. GERMANY II.3. LUXEMBOURG II.3. KOREA II.3. NORWAY II.3. PORTUGAL II.3. SWITZERLAND II.3. UNITED STATES 61 62 62 62 62 62 63 63 Part II, Table 4 64 II.4. AUSTRIA II.4. BELGIUM II.4. CANADA II.4. CHILE II.4. FINLAND 64 64 65 65 65 3 II.4 FRANCE II.4. GERMANY II.4. GREECE II.4. HUNGARY II.4. IRELAND II.4. ISRAEL II.4. ITALY II.4. KOREA II.4. MEXICO II.4. NETHERLANDS II.4. NORWAY II.4. PORTUGAL II.4. SLOVENIA II.4. SWITZERLAND II.4. UNITED STATES 66 66 67 68 69 69 70 71 71 71 71 72 72 72 72 PART III. SOCIAL SECURITY CONTRIBUTION TABLES 72 Part III, Table 1 72 III.1. AUSTRIA III.1. BELGIUM III.1. CANADA III.1. CHILE III.1. CZECH REPUBLIC III.1. GERMANY III.1. GREECE III.1. ISRAEL III.1. LUXEMBOURG III.1. MEXICO III.1 NETHERLANDS III.1. POLAND III.1. SLOVAK REPUBLIC III.1. SLOVENIA III.1. SPAIN III.1. SWEDEN III.1. UNITED KINGDOM 72 73 77 78 79 79 79 80 82 82 82 84 85 87 88 90 90 Part III, Table 2 92 III.2. AUSTRIA III.2. BELGIUM III.2. CANADA III.2. CHILE III.2. CZECH REPUBLIC III.2. GREECE III.2. IRELAND III.2. ISRAEL III.2. LUXEMBOURG III.2. MEXICO III.2. NETHERLANDS III.2. NORWAY III.2. POLAND 92 92 94 95 95 96 96 96 97 97 97 100 100 4 III.2. SLOVAK REPUBLIC III.2. SPAIN III.2. SWEDEN III.2. UNITED KINGDOM III.2 UNITED STATES 100 102 102 102 103 Part III, Table 3 103 III.3. AUSTRIA III.3. BELGIUM III.3. CANADA III.3. CHILE III.3. CZECH REPUBLIC III.3. GERMANY III.3. GREECE III.3. IRELAND III.3. ISRAEL III.3. ITALY III.3. KOREA III.3. MEXICO III.3. NDS III.3. NORWAY III.3. POLAND III.3. PORTUGAL III.3. SLOVAK REPUBLIC III.3. SLOVENIA III.3. SPAIN III.3. SWEDEN III.3. TURKEY III.3. UNITED KINGDOM 103 103 104 104 105 105 105 107 107 108 109 109 111 111 111 112 112 113 115 116 116 117 5 PART I. TAXATION OF WAGE INCOME Note to Part I, Tables 4 to 7 Part I Tables I.4-I.7 are based on a methodology elaborated in the annual OECD publication ‘Taxing Wages’, examining taxes paid on wage income in OECD countries. Tables I.4-I.5 generate marginal and average tax rates on wage income for single individuals, while Table I.6 considers a broader range of household cases, and Table I.7 sets out the top marginal personal tax rates where the highest statutory tax rate first applies. The ‘Taxing Wages’ framework analyses personal income tax, social security contributions paid by employees and their employers, and cash benefits received by families with children, and how these taxes and benefits impact on net household incomes. The ‘Taxing Wages’ publication considers eight household cases, analysing marginal and average tax rates on wage incomes of single individuals, one-earner and two-earner married couples, with and without children. It is assumed that their annual income from employment is equal to a given fraction of the average gross wage earnings of adult, full-time workers in the manufacturing sector of each OECD economy. Any income tax that might be due on non-wage income, as well as, all other kinds of taxes – e.g., corporate income tax, net wealth tax and consumption tax – are not taken into account. Personal average tax rate (or “tax burden”) is the term used when personal income tax and employees’social security contribution are expressed as a percentage of gross wage earnings. Tax wedges – between labour costs to the employer and the corresponding net take-home pay of the employee – are calculated by expressing the sum of personal income tax, employee plus employer social security contributions together with any payroll tax, as a percentage of labour costs. To determine labour costs, employer social security contributions and – in some countries – payroll taxes must be added to gross wage earnings of employees. The gross wage earnings used are either provided by the country or they are estimates derived by the Secretariat using the latest available country estimate and projecting this amount using the annual percentage change in wages reported in the most recently published edition of the OECD Economic Outlook. It should be noted that the figures provided in Tables I.4 to I.7 may be different from those published in the publication Taxing Wages. These differences will arise where updated information becomes available such as new APW figures or where there have been methodological changes. The user is encouraged to consult the Taxing Wages publication for more information. AUSTRALIA In the 1999-00 financial year the Medicare levy was classified as an employee SSC. From 2000-01 the Medicare levy was classified as an element of the central government tax rate. AUSTRIA In Tables 4 and 5, the total tax wedges include payroll taxes of 7.5 per cent of gross wage. 6 ITALY The most representative city is Rome, located in the region Lazio. Therefore the combined top marginal rate includes: a) the regional surcharge tax levied in Lazio at a rate of 1.73%. b) the local surcharge tax levied in Rome at a rate of 0.9%. See the explanatory notes to table 1.6 for further details on regional and local surcharge taxes. MEXICO As reported on ‘Taxing Wages’, social security contributions do not include those made by employers and employees to privately managed retirement funds (AFORES), or to the INFONAVIT housing fund. In Mexico there is no special tax treatment to married individuals or families with children, therefore, the rates reported in Table I.6 are the same in all cases. 7 Part I, Table 1 I.1. AUSTRIA In 2009, there was a change to a new tax schedule: Incomes up to 11 000€ are tax-free (zero-zone), the general tax credit was abolished. The formulas to calculate the tax are presented in the tax law. The rates shown in table I.1 are the marginal tax rates. The marginal tax rate (top rate) for incomes above 60 000€ has remained unchanged at 50%. I.1. BELGIUM Standard tax allowance A standard tax allowance is applicable starting from the first income bracket. Since 2004 the standard tax allowance of married persons and singles are equal. From 2008 onwards, earners of relatively low aggregated taxable income (ATI, see table) benefit from an increased standard tax allowance. ATI ≤ 22 870 6 400 2009 and 2010 Income (euros) Allowance (euros) ATI ≤ 23 900 6 690 Between 22 870 and 23 100 6 400 – (ATI – 22 870) Between 23 900 and 24 160 6 690 – (ATI – 23 900) 23 100 ≤ ATI 6 150 24 160 ≤ ATI 6 430 Income (euros) 2008 Allowance (euros) 2012 Income (euros) ATI ≤ 25 270 Between 25 270 and 25 540 25 540 ≤ ATI In euros Singles Married persons In BEF Singles Married persons 1989 2013 Allowance (euros) 7 070 7 070 – (ATI – 25 270) 6 800 2000 5 205.76 (210 000 BEF) 4 139.82 (167 000 BEF) 1990 2011 Income Allowance (euros) (euros) ATI ≤ 24 6 830 410 Between 6 830 – 24 410 (ATI – 24 and 24 410) 670 24 670 ≤ 6 570 ATI Income (euros) ATI ≤ 25 990 Between 25 990 and 26 270 26 270 ≤ ATI 2001 5 350 (215 818 BEF) 4 240 (171 041 BEF) 1991 1992 Allowance (euros) 7 270 7 270 – (ATI – 25 990) 6 990 2002 2003 2004 2005 2006 2007 5 480 5 570 5 660 5 780 5 940 6040 4 350 4 610 5 660 5 780 5 940 6040 1993 1994 165 000 170 000 176 000 181 000 186 000 191 000 130 000 134 000 139 000 143 000 146 000 150 000 1995 1996 1997 1998 1999 196 000 154 000 198 000 156 000 203 000 160 000 206 000 162 000 208 000 165 000 Crisis surcharge From 1993 onwards a 3% crisis surcharge was levied on personal income tax (Contribution complémentaire de crise, C.C.C.). The surcharge was gradually repealed between 2000 and 2002, when the rate became function of the aggregated taxable income (ATI) of the household. The surcharge on PIT has 8 been abolished from 2003 on.. Belgian Surtax in 2002: ATI bracket in euros. 29 747.24 or less Between 29 747.25 and 30 986.70 30 986.70 and over Surtax rate 0% 1 % (ATI – 29 747.24) /1 239.46 1% 1 Euro = 40.3399 BEF In 2000 and 2001: ATI bracket in BEF 800 000 or less Between 800 000 and 850 000 Between 850 000 and 1 200 000 Between 1 200 000 and 1 250 000 1 250 000 and over Surtax rate 2000 1% 1% + 1% (ATI – 800 000)/50 000 2% 2% + 1% (ATI – 1 200 000)/50 000 3% Surtax rate 2001 0% 1 % (ATI - 800 000) /50 000 1% 1%+ 1 % (ATI – 1 200 000)/50 000 2% I.1. CHILE Salaries, pensions (except those from a foreign source) and other remunerations are taxed on a monthly basis via the Second Category Unique Income Tax. The tax base is gross salary and work compensations less social security payments. The thresholds are expressed in the Monthly Tax Unit (Unidad Tributaria Mensual - UTM), which is an accounting unit for tax purposes that is adjusted monthly according to the change in the Consumer Price Index in the previous month. The UTM values in Chilean pesos in December of each year were: Year UTM 2000 27,600 2001 28,524 2002 29,389 2003 29,739 2004 2005 30,308 2006 32,206 2007 34,222 2008 37,652 2009 36,863 2010 37,605 2011 39,021 2012 40,206 31,571 Personal income, from all sources, is then taxed annually via the Global Complementary Tax. The thresholds for this tax are expressed in the Annual Tax Unit (Unidad Tributaria Anual -UTA), which is equal to the December UTM, multiplied by twelve. The UTA values in Chilean pesos in December of each year were: 9 Year UTA 2000 331,200 2001 342,288 2002 352,668 2003 356,868 2004 2005 363,696 2006 386,472 2007 410,664 2008 451.824 2009 442,356 451,260 2010 378,852 2011 468,252 2012 482,472 Both the above taxes have identical tax brackets and threshold figures, but are expressed in different unities as explained above. Tax thresholds in the table rates are calculated by applying the following multiples to the UTM, in case of the Second Category Unique Income Tax, or to the December UTA, if it corresponds to the Global Complementary Tax: Taxable income (UTA – UTM) 0 – 13.5 Tax rates exempt 13.5 – 30 30 – 50 4% 8% 50 – 70 13.5% 70 – 90 23% 90 – 120 30.4% 120 – 150 35.5% 150 and over 40% : New tax rates levied as of 2013. Individuals and legal entities that are not resident or domiciled in Chile are generally taxed on any income derived from Chilean sources via the Additional Tax, at a standard tax rate of 35% (lower rates applies for some types of income). I.1. FINLAND A standard deduction for work-related expenses equal to the amount of wage or salary, with a maximum amount of EUR 620 is granted. 10 An earned income tax credit is granted against the central government income tax. If the credit exceeds the amount of central government income tax, the excess credit is deductible from the municipal income tax and the health insurance contribution for medical care. The credit is calculated on the basis of taxpayers’ income from work. The credit amounts to 7.3 per cent of income exceeding EUR 2 500, until it reaches its maximum of EUR 970. The amount of the credit is reduced by 1.1 per cent of the earned income minus work related expenses exceeding EUR 33 000. The credit is fully phased out when taxpayers’ income is about EUR 120 000. I.1. GERMANY The German personal income tax schedule is formula-based. Since 2004 the calculations are based on a down to the next (full) EUR rounded amount of taxable income. X is the taxable income. T is income tax liability. Definitions and formulas as of 2014 (amounts in EUR): Y = (X – 8 354) / 10 000 Z = (X – 13 469) / 10 000 1. T = 0 for X 8 354 2. T = (974.58 Y + 1 400) Y for 8 355 3. T = (228.74 Z + 2 397) Z + 971 for 13 470 4. T = 0.42 X – 8 239 for 52 882 X 250 730 5. T = 0.45 X – 15 761 for 250 731 X 13 469 X 52 881 Definitions and formulas since 2013 (amounts in EUR): Y = (X – 8 130) / 10 000 Z = (X – 13 469) / 10 000 1) T = 0 for X 8 130 2) T = (933.70 Y + 1 400) Y for 8 131 13 469 3) T = (228.74 Z + 2 397) Z + 1 014 for 13 470 4) T = 0.42 X – 8 196 for 52 882 X 250 730 5) T = 0.45 X – 15 718 for 250 731 X X 52 881 Definitions and formulas from 2010 until 2012 (amounts in EUR): Y = (X – 8 004) / 10 000 Z = (X – 13 469) / 10 000 11 T = 0 for X 8 004 T = (912.17 Y + 1 400) Y for 8 005 13 469 T = (228.74 Z + 2 397) Z + 1 038 for 13 470 X 52 881 T = 0.42 X – 8 172 for 52 882 X 250 730 T = 0.45 X – 15 694 for 250 731 X Definitions and formulas in 2009 (amounts in EUR): Y = (X – 7 834) / 10 000 Z = (X – 13 139) / 10 000 T = 0 for X 7 834 T = (939.68 Y + 1 400) Y for 7 835 13 139 T = (228.74 Z + 2 397) Z + 1 007 for 13 140 T = 0.42 X – 8 064 for 52 552 X 250 400 T = 0.45 X – 15 576 for 250 401 X Definitions and formulas in 2007 and 2008 (amounts in EUR): Y = (X – 7 664) / 10 000 Z = (X – 12 739) / 10 000 T = 0 for X 7 664 T = (883.74 Y + 1 500) Y for 7 665 X 12 739 T = (228.74 Z + 2 397) Z + 989 for 12 740 X 52 151 T = 0.42 X - 7 914 for 52 152 X 250 000 T = 0.45 X – 15424 for 250 001 X Definitions and formulas in 2005 and 2006 (amounts in EUR): Y = (X – 7 664) / 10 000 Z = (X – 12 739) / 10 000 T = 0 for X 7 664 12 T = (883.74 Y + 1 500)Y for 7 665 12 739 T = (228.74 Z + 2 397) Z + 989 for 12 740 52 151 T = 0.42 X – 7 914 for 52 152 X Definitions and formulas in 2004 (amounts in EUR): Y = (X – 7 664) / 10 000 Z = (X – 12 739) / 10 000 1. 2. 3. 4. T = 0 for X 7 664 T = (793.10 Y + 1 600) Y for 7 665 12 739 T = (265.78 Z + 2 405) Z + 1 016 for 12 740 52 151 T = 0.45 X – 8 845 for 55 152 X Up to 2003 the calculations were based on a rounded amount of taxable income. If the taxable income could not be divided by 36, it was rounded down to the next (full Euro) amount which could be divided by 36. Subsequently it was increased by EUR 18. Definitions and formulas in 2002 and 2003 (amounts in EUR): Y = (X – 7 200) / 10 000 Z = (X – 9 216) / 10 000 1. 2. 3. 4. T = 0 for X 7 235 T = (768.85Y + 1 990)Y for 7 236 X 9 251 T = (278.65Z + 2 300)Z + 432 for 9252 55 007 T = 0.485X – 9 872 for 55 008 X Definitions and formulas in 2001 (amounts in DM): Y = (X - 14 040) / 10 000 Z = (X – 18 036) / 10 000 1. 2. 3. 4. T = 0 for X 14 093 T = (387.89Y + 1 990) Y for 14 094 X T = (142.49Z + 2 300) Z + 857 for 18 090 X 107 567 T = 0.485X – 19 299 for 107 568 X Definitions and formulas in 2000 (amounts in DM): Y = (X – 13 446) / 10 000 Z = (X – 17 442) / 10 000 1. 2. 3. 4. T = 0 for X 13 499 T = (262.76Y + 2 290) Y for 13 500 X 17 495 T = (133.74Z + 2 500) Z + 957 for 17 496 X T = 0.51X – 20 575 for 114 696 X 13 These formulae are used directly to calculate the income tax of single individuals. The income tax liability for spouses who are assessed jointly is computed as follows: the formula income tax is calculated with respect to one-half of the joint taxable income. The resulting amount is doubled to arrive at the income tax liability of the spouses (splitting method). I.1. ITALY In 2003, the Financial Law introduced an allowance system for employees, self-employed and pensioners, varying with income. For employees the standard allowance for wage income (“no tax area”) was € 7 500. The actual allowance granted to each individual depended on the value of a ratio that was defined as a function of net income: (26000 + 7500 – net income) / 26000 calculated as follows: ratio > or = 1 0 < ratio < 1 ratio < or = 0 Actual allowance = Standard allowance Actual allowance = 7 500.00 * ratio Actual allowance = 0 Only for the years 2003 and 2004 tax credits were still applied for employed workers, varying with income as follows: INCOME TAX CREDIT From € 27 000.00 to € 29 500.00 € 130.00 From € 29 500.01 to € 36 500.00 From € 36 500.01 to € 41 500.00 € 235.00 € 180.00 From € 41 500.01 to € 46 700.00 € 130.00 From € 46 700.01 to € 52 000.00 € 25.00 In 2005 the Financial Law introduced: new tax rates and income brackets; conversion of tax credits for family dependents into tax allowances abolition of tax credits for employees, self-employed and pensioners. The personal allowances for family dependents (family area”) were calculated as follows: maximum tax allowances for family dependents: Spouse Child child under three years of age first child (single parent) disabled child other dependent relatives 3,200 € 2,900 € 3,450 € 3,200 € 3,700 € 2,900 € The actual allowance granted to each individual depended on the value of a ratio that was defined as a function of net income: 14 (78000 + maximum family allowance – net income) / 78000 and was calculated as follows: ratio > or = 1 0 < ratio < 1 ratio < or = 0 Actual allowance = maximum family allowance Actual allowance = maximum family allowance * ratio Actual allowance = 0 Tax allowances for children could be distributed between parents to allow them to take full advantage of these allowances. In 2007 a new tax credits system has replaced the former system of tax allowances : PAYE tax credits Amount Up to 8,000 1,840 From 8,001 to 55,000 1,840 decreasing up to 0 on the basis of a ratio defined as a function of net income More than 55,000 0 Tax credits for pensions Up to 7,500 Amount 1,725 1,725 decreasing up to 0 on the basis of a ratio defined as a function of net income 0 From 7,501 to 55,000 More than 55,000 For pensioners who are 75 years old or more the tax credits described above are slightly higher. Tax credits for self-employed Up to 4,800 From 4,801 to 55,000 More than 55,000 Amount 1,104 1,104 decreasing up to 0 on the basis of a ratio defined as a function of net income 0 For employees the formula to calculate the tax credit is: Taxable income (EUR) Up to 8,000 From 8,001 to 15,000 From 15,001 to 55,000 More than 55,000 PAYE tax credit (EUR) 1,840 Maximum tax credit + 502*(15,000 – taxable income)/7,000 Maximum tax credit*(55,000 – taxable income)/40,000 0 The maximum tax credit mentioned in the table above depends on the level of taxable income: Level of taxable income (EUR) From 8 001 to 15 000 From 15 001 to 23 000 From 23 001 to 24 000 From 24 001 to 25 000 From 25 001 to 26 000 From 26 001 to 27 700 From 27 701 to 28 000 From 28 001 to 55 000 Maximum tax credit (EUR) 1 338 1 338 1 348 1 358 1 368 1 378 1 363 1 338 15 Tax credits for family dependants have replaced the former tax allowances as follows: Family tax credits Amount Spouse 800 decreasing up to 0 for net income over 80.000 Children Under three years of age (*) Over three years of age (*) 1,220 decreasing up to 0 for net income over 95,000 950 decreasing up to 0 for net income over 95,000 Other dependent relatives 750 decreasing up to 0 for net income over 80.000 (*) For families with disabled children the amount of tax credits is 400 euros higher for each child (*) For families with more than 3 children the amount of tax credits is 200 euro higher for each child. Families with more than 3 children that benefit from tax credits for family dependants are also entitled to an addition tax credit of euros 1,200 The spouse tax credit is calculated as a function of net income: Level of taxable income (EUR) Up to 15 000 From 15 001 to 29 000 From 29 001 to 29 200 From 29 201 to 34 700 From 34 701 to 35 000 From 35 001 to 35 100 From 35 101 to 35 200 From 35 201 to 40 000 From 40 001 to 80 000 More than 80 000 Amount of tax credit (EUR) 800 – 110*taxable income/15 000 690 700 710 720 710 700 690 690*(80 000 – taxable income)/40 000 0 The child tax credit is calculated as a function of net income: for families with only one child: 950*(95 000 – taxable income)/95 000; for families with more than one child the amount of 95 000 is increased by 15 000 for each child other than the first, for every children A lone parent receives an actual tax credit for the first child equal to the maximum between the spouse tax credit and the child tax credit. Tax credits for children have to be equally shared between the parents; however, parents can decide to assign the entire amount of the tax credit to the spouse earning the higher income. I.1. LUXEMBOURG The following tables show the thresholds and marginal rates plus the top rate from 2001 to 2013: 16 2001 marginal threshold rate 9 668 11 378 13 089 14 799 16 510 18 220 19 931 21 641 23 352 25 062 26 773 28 483 30 193 31 904 33 614 14% 16% 18% 20'% 22% 24% 26% 28% 30% 32% 34% 36% 38% 40% 42% 2009 - 2010 Threshold 11265 13173 15081 16989 18897 20805 22713 24621 26529 28437 30345 32253 34161 36069 37977 39885 Marginal rate 8% 10% 12% 14% 16% 18% 20% 22% 24% 26% 28% 30% 32% 34% 36% 38% 2002-2007 2008 threshold marginal rate threshold marginal rate 9750 11400 13050 14700 16350 18000 19650 21300 22950 24600 26250 27900 29550 31200 32850 34500 8% 10% 12% 14% 16% 18% 20% 22% 24% 26% 28% 30% 32% 34% 36% 38% 10335 12084 13833 15582 17331 19080 20829 22578 24327 26076 27825 29574 31323 33072 34821 36570 8% 10% 12% 14% 16% 18% 20% 22% 24% 26% 28% 30% 32% 34% 36% 38% Since 2011 Since 2013 Threshold Marginal rate Threshold Marginal rate 11265 13173 15081 16989 18897 20805 22713 24621 26529 28437 30345 32253 34161 36069 37977 39885 41793 8% 10% 12% 14% 16% 18% 20% 22% 24% 26% 28% 30% 32% 34% 36% 38% 39% 11265 13173 15081 16989 18897 20805 22713 24621 26529 28437 30345 32253 34161 36069 37977 39885 41793 100000 8% 10 12% 14% 16% 18% 20% 22% 24% 26% 28% 30% 32% 34% 36% 38% 39% 40% I.1. MEXICO The figure reported under the heading “Personal allowance / tax credit” includes the maximum personal allowance and the maximum tax credit as defined in ‘Taxing Wages’. The maximum personal 17 allowance was calculated by adding the maximum amount deductible of the end-of year-bonus (30 days of the minimum legal wage) and the holiday bonus (15 days of the minimum legal wage). In the column “personal allowance/ tax credit” the information for Mexico includes both a personal allowance and a tax credit. The following table presents the composition of the aggregated number reported on Table I.1 for the period 1981 to 2013. Year Employment subsidy 1/ 2/ Holiday and end of year bonuses Personal allowance / Tax credit 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 66,813.25 89,362.95 145,302.85 218,510.90 342,665.65 538,192.50 1,007,702.95 2,569,851.85 285,928.59 333,569.49 393,710.17 441,066.73 476.69 902.94 1,274.64 2,001.69 2,566.62 2,984.76 3,584.34 3,966.21 4,228.14 4,276.20 4,324.20 4,324.20 4,884.24 4,884.24 4,884.24 5,491.50 7,344.90 11,942.70 17,959.80 28,164.30 44,235.00 82,824.90 316,831.05 352,514.70 411,250.05 485,396.10 543,780.90 587.70 628.65 672.75 829.35 1,093.50 1,259.55 1,435.95 1,580.40 1,690.65 1,788.30 1,868.85 1,948.05 2,035.80 2,117.25 2,199.60 72,304.75 96,707.85 157,245.55 236,470.70 370,829.95 582,427.50 1,090,527.85 2,886,682.90 638,443.29 744,819.54 879,106.27 984,847.63 1,064.39 1,531.59 1,947.39 2,831.04 3,660.12 4,244.31 5,020.29 5,546.61 5,918.79 6,064.50 6,193.05 6,272.25 6,920.04 7,001.49 7,083.84 2008 4,884.24 2,287.80 7,172.04 2009 4,884.24 2,393.55 7,277.79 2010 4,884.24 2,509.65 7,393.89 2011 4,884.24 2,612.70 7,496.94 2012 4,884.24 2,722.50 7,606.74 4,884.24 2,840.40 7,724.64 2013 1/ Starting in 1993 the value of the Mexican peso changed, being one peso of 1993 equal to one thousand pesos of 1992. 2/ In the 2008 Tax Reform the salary tax credit changed its name to the employment subsidy; however, the benefit for workers remained the same. 18 I.1. NETHERLANDS The tax brackets to and rates for employees under the retirement age are:Income from labour and dwellings from tax rate employees SSC combined rate rate (general scheme) 0 19,645 5.85% 31.15% 37.0% 19,645 33,555 10.85% 31.15% 42.0% 33,555 55,991 42% - 42% 52% - 52% 55,991 For employees, most of the personal income tax and employees SSC’s is withheld by the employer through the wage tax. Withheld wage tax is generally creditable to the personal income tax. In 2013, a once-only surtax in the wage tax aforementioned of 16% of wages exceeding € 150,000 is effective. This surtax has to be paid by the employer. I.1. NORWAY Personal income (i.e. ordinary income) is taxed with a 28 per cent flat rate in most of the country. Ordinary income includes all income (e.g. from labour, capital and pensions) less allowances. The revenue from the personal income tax on ordinary income is split between three levels of government: central, state and local. The split is decided upon by the Parliament as part of the National Budget. The central government tax rate between the personal allowance and the first threshold level is, therefore, the central government revenue share of tax on ordinary income. For municipalities in the northernmost parts of Norway, a reduced flat rate of 24.5 per cent applies. The reduction is in the central government part of the income tax revenue. The personal income tax rate on ordinary income is the same as the corporate tax rate. Any change in the rate will thus apply for both corporate and personal income tax. I.1. POLAND Personal income tax was introduced in year 1992. Personal income tax is levied on all kinds of income divided into individual sources. The income from a given source of revenue is considered as the excess of the total of revenue from that source over the tax deductible costs, generated in a given tax year. Generally if the taxpayer receives income from more than one source a sum of the income from all sources is subject to taxation. However, the loss incurred over the fiscal year may lower the income derived only from that source of revenue for five subsequent fiscal years (no more than 50% of the amount of loss in any of the years). 19 The tax schedule is as follows: Tax base (in PLN) Tax amount Over Below 0 85 528 85 528 18% of the tax base, less a basic tax credit of PLN 556.02 PLN 14 839.02 + 32% of surplus over PLN 85 528 Individuals are taxed on their own income, but couples married during the whole calender year can opt to be taxed on their joint income.Provisions of the PIT Act do not apply to (mainly): revenue from agricultural activities (except for revenue from the so-called „special branches of agricultural production”) and from forestry; revenue falling under the provisions of the Act on Inheritance and Donation Tax. The personal income tax is the central government tax but revenue from this tax is split between central government and local governments. I.1. SLOVAK REPUBLIC In 1998 and 1999 the progressive tax rates were in effect; six tax brackets were established, with the rates ranging from 15 to 42 percent. For more detail see the following table. 20 Tax brackets % of tax base exceeding the minimum threshold from to fix value 0 1 992 3 983 5 975 17 925 35 849 1 992 3 983 5 975 17 925 35 849 and more 299 697 1 195 5 019 12 189 15% 20% 25% 32% 40% 42% 1 1. As of 1st January we adopted euro currency, so all tax brackets were correspondingly calculated according to conversion rate (1 euro = SKK 30.126), the values are rounded Moreover, special taxation for high income individuals (the surtax) was introduced. If the tax base exceeded SKK 1,080,000, the final calculated tax was additionally taxed according to the following table: Value of calculated tax from to Additional taxation 12 189 42 302 5% 42 302 132 643 10% 132 643 298 267 20% and more 30%.2 298 267 st 2. As of 1 January we adopted euro currency, so all tax brackets were correspondingly calculated according to conversion rate (1 euro = SKK 30.126), the values are rounded As from 2012 non-taxable dividend income (dividends are not taxed at all) in Slovak republic are subject to health insurance contributions. The rate applied for health contribution from dividend is equal to 10% and the maximum assessment base is equal to 36-times of average wage per year. As from 2013 the rate has been increased from 10% to 14% and maximum assessment base has been increased to 120-times of the average wage per year. I.1. SLOVENIA Between 2000 and 2005 all taxable income was aggregated on an annual basis and taxed at progressive rates taking account of the appropriate allowances and deductions. From 2006, the system changed to a kind of dual income system where the majority of income (ie such as from employment, business , agriculture and forestry, rents and royalties) continued to be aggregated and taxed as a whole whereas income from capital (ie interest, dividends and capital gains) has been taxed at proportionate rates on a schedular basis. The tax rates applying to the latter between 2006 and 2013 have been as follows: Interest - 15% in 2006 and 2007; 20% from 2008 to 2012, 25 % from 2013 Dividends - 20% till 2012, 25 % from 2013 21 Capital gains - Regressive rates declining from 25 per cent to nil depending on the holding period. The zero rate applies when the holding period is 20 years or more. Till 2012 the top rate was 20 % I.1. SPAIN Since 1 January 2007 a new system of personal and family allowances apply. Concretely for the 2013 tax period the following personal and family allowances are granted to taxpayers: a personal allowance of € 5 151 for individual taxpayers under 65 years of age (filing individually or jointly tax returns) Taxpayers over 65 years old are granted with an additional allowance of € 918, and taxpayers older than 75 may increase (additionally as well) their personal allowance by € 1 122 A family allowance for dependent children of € 1 836 for the first child; € 2 040 for the second child; € 3 672 for the third child, and € 4 182 for any other child A childcare allowance of € 2 244 for children under 3 years of age Taxpayers’ ascendant allowance of € 918 for each dependent ascendant older than 65 years of age, and an additional allowance of € 1 122 for those older than 75 years of age Disabled taxpayer allowance of € 2 316 per taxpayer and for each entitled disabled ascendant/descendant. An increased allowance of € 7 038 for severely disabled taxpayers and ascendants/descendants is also applied. Additionally, those taxpayers requiring third person’s assistance or with reduced mobility are granted with a € 2 316 allowance Personal and family allowances are not taxed because they are subject to a zero tax rate. Different types of income are pooled and offset according to its source, and are classified in two parts: the general income tax base and the saving income tax base Next table shows general government tax rates to be applied to the general tax base during 2012 & 2013 Net tax base Up to € Gross amount due € Rest of tax base Up to € Tax rate % 0.00 17,707.20 33,007.20 53,407.20 120,000.20 175,000.20 300,000.20 0.00 2,557.67 4,705.67 9,091.67 26,072.88 41,197.88 78,072.88 17,707.20 15,300.00 20,400.00 66,593.00 55,000.00 125,000.00 above 12.75 16.00 21.50 25.50 27.50 29.50 30,50 The savings tax base for tax years 2012 & 2013 is subject to the following tax rates: Net tax base Up to € Gross amount due € Rest of tax base Up to € Tax rate % 22 0.00 6,000.00 24,000.00 0.00 690.00 3,390.00 6,000.00 18,000.00 above 11.50 14.50 16.50 Since 1 January 2003 the personal allowance granted for each individual reaches the amount of € 3 400. For married couples filing jointly the allowance amounts to € 3 400 for each household member. This figure is € 5 550 for heads of households. The following amounts apply for tax years prior to 2003: A personal allowance of € 3 305.57 (ESP 550 000 in the last few years) is granted for each individual. For married couples filing jointly the allowance amounts to € 6 611.13 (ESP 1 110 000 in the last few years). This figure is € 5 409.11 (ESP 900 000 in the last few years) for heads of households. I.1. SWITZERLAND The reported central government personal income tax rates and thresholds for single people without children. The central government personal income tax rates and thresholds as of 2012 for married couples and singles with children are as follows: Rate per cent 0 1 2 3 4 5 6 7 8 9 10 11 12 13 Ceiling (SFR) 28 300 50 900 58 400 75 300 90 300 103 400 114 700 124 200 131 700 137 300 141 200 143 100 145 000 895 900 Tax amounts under CHF 25 are not levied. Above CHF 755 200 for a single person and CHF 895 800 for married couples and singles with children, all income is taxed at a flat rate of 11.5 per cent. Married couples are taxed jointly. I.1. UNITED KINGDOM Taxable income is defined as gross income for income tax purposes less allowances and reliefs available at the marginal rate. In 2010-11, taxpayers are liable at the starting rate of 10 per cent on the first £2 440 of savings income unless their non-savings income exceeds the starting rate limit. Taxpayers without savings income in the starting rate band are liable at the basic rate of 20 per cent on the first £37 400 of all income except for dividends where the rate is 10 per cent. The rate of tax on taxable income between £37 400 and £150,000 is 40 per cent except for dividend income where it is 32.5 per cent. The rate of tax on taxable incomes in excess of £150,000 is 50 per cent except for dividend income where it was 42.5 per cent. 23 From April 2010 the Personal allowance was reduced for individuals with incomes after deductions in excess of £100,000 at a rate of £1 of allowance for every £2 on income. In 2010-11, the Personal Allowance was £6,475 and therefore was tapered to zero by £112,950. From April 2008 the the basic rate for non-savings income was reduced from 22 per cent to 20 per cent and the 10 per cent starting rate band was removed for non-savings income. There is now a 10 per cent starting rate for savings income only. Previously taxpayers were liable at the starting rate of 10 per cent on the first £2 230 in 2007-08 of all taxable income. On the next £32 370 in 2007-08 they were liable at the basic rate of 22 per cent on all income except for dividends and other savings income where the rates were 10 per cent and 20 per cent respectively. The rate of tax on taxable income over £34 600 in 2007-08 was 40 per cent except for dividend income where it was 32.5 per cent. Before Independent taxation was introduced in 1990, the tax system tended to treat married couples as one unit for income tax purposes and gave married men a higher personal allowance than single taxpayers. These are given in the table below. In addition, wives’ earnings received an additional relief or allowance. Year 1981-82 1982-83 1983-84 1984-85 1985-86 1986-87 1987-88 1988-89 1989-90 Personal allowance for married men 2,145 2,445 2,795 3,155 3,455 3,655 3,795 4,095 4,375 I.1. UNITED STATES Beginning in 2001, a 10 per cent tax rate was added that applies to the first $6,000 of taxable income ($7,000 in 2003). The taxable income threshold is adjusted for inflation. Part I, Table 2 I.2. BELGIUM The representative sub-central government tax rate is an average of sub-central rates. From 2002, the regions may set a flat or progressive surtax or rebate based upon the federal PIT. Starting from 1.1.2007 a rebate was introduced for taxpayers liable to personal income tax living in the Flemish Region and having a yearly net earned income (NEI), excluding replacement income and excluding separately taxed income, of at least 5 500 euro. The Flemish rebate was abolished from 1.1.2011.. 2010 Net earned income (NEI) in € NEI < 5 500.00 5 500.00 ≤ NEI ≤ 17 250.00 17 250.00 ≤ NEI ≤ 18 500.00 Flemish rebate in € 0 125.00 125.00 – 0.10 (NEI – 17.250,00) 24 NEI > 18 500.00 0 2009 Net earned income (NEI) in € NEI < 5 500.00 5 500.00 ≤ NEI ≤ 22 000.00 NEI > 22 000.00 Flemish rebate in € 0 300.00 250.00 2008 Net earned income (NEI) in € NEI < 5 500.00 5 500.00 ≤ NEI ≤ 21 000.00 21 000.00 < NEI ≤ 23 000.00 NEI > 23 000.00 Flemish rebate in € 0 200.00 200.00 - 0.10 (NEI – 21 000.00) 0 2007 Net earned income (NEI) in € NEI < 5 500.00 5 500.00 ≤ NEI ≤ 21 000.00 21 000.00 < NEI ≤ 22 250.00 NEI > 22 250.00 Flemish rebate in € 0 125.00 125.00 - 0.10 (NEI – 21 000.00) 0 I.2. CANADA The representative sub-central government tax rate is for the Province of Ontario, where the largest city in Canada, Toronto is located. Starting in 2000 most provinces, with the exception of Quebec, have adopted a new approach to calculating provincial Personal Income Taxes. The Federal Government had agreed to administrate provincial income tax as a percentage of Taxable Income rather than as a percentage of Basic Federal Tax. In addition, some provinces impose a provincial surtax. Provincial Income Tax Rates: Basic Provincial Tax 2013 (1) Province Newfoundland Prince Edward Island Nova Scotia New Brunswick (2) Taxable income 0 – 33 748 33 748 – 67 496 67 496 and over 0 – 31 984 31 984 – 63 969 63 969 – and over 0 – 29 590 29 590 – 59 180 59 180 – 93 000 93 000 – 150 000 150 000 and over 0 – 38 954 38 954 – 77 908 2012 (3) (4) Rate Surtax 7.70 12.50 13.30 9.80 13.80 16.70 8.79 14.95 16.67 17.50 21.00 9.39 13.46 10 (5) Taxable income 0 – 32 893 32 893 – 65 785 65 785 and over 0 – 31 984 31 984 – 63 969 63 969 – and over 0 – 29 590 29 590 – 59 180 59 180 – 93 000 93 000 – 150 000 150 000 and over 0 – 38 190 38 190 – 76 380 (6) (7) Rate Surtax 7.70 12.50 13.30 9.80 13.80 16.70 8.79 14.95 16.67 17.50 21.00 9.10 12.10 10 25 Ontario Manitoba Saskatchewan Alberta British Columbia Quebec** 77 908 – 126 662 126 662 and over 0 – 39 723 39 723 – 79 448 79 448 – 509 000 509 000 and over 0 – 31 000 31 000 – 67 000 67 000 and over 0 – 42 906 42 906 – 122 589 122 589 and over All income 0 – 37 568 37 568 – 75 138 75 138 – 86 268 86 268 – 104 754 104 754 and over 0 – 41 095 41 095 – 82 190 82 190 – 100 000 100 000 and over 14.46 16.07 5.05 9.15 11.16 13.16 10.80 12.75 17.40 11.00 13.00 15.00 10.00 5.06 7.70 10.50 12.29 14.70 16.00 20.00 24.00 25.75 20 – 56 76 380 – 124 178 124 178 and over 0 – 39 020 39 020 – 78 043 78 043 –500 000 500 000 and over 0 – 31 000 31 000 – 67 000 67 000 and over 0 – 42 065 42 065 – 120 185 120 185 and over All income 0 – 37 013 37 013 – 74 028 74 028 – 84 993 84 993 – 103 205 103 205 and over 12.40 14.30 5.05 9.15 11.16 12.16 10.80 12.75 17.40 11.00 13.00 15.00 10.00 5.06 7.70 10.50 12.29 14.70 0 – 40 100 40 100 – 80 200 80 200 and over 16.00 20.00 24.00 2011 (1) Province Newfoundland Prince Edward Island Nova Scotia New Brunswick Ontario Manitoba Saskatchewan Alberta British Columbia 20 – 56 2010 (2) (3) (4) (5) (6) (7) Taxable income Rate Surtax Taxable income Rate Surtax 0 – 31 904 31 904 – 63 807 63 807 and over 0 – 31 984 31 984 – 63 969 63 969 – and over 0 – 29 590 29 590 – 59 180 59 180 – 93 000 93 000 – 150 000 150 000 and over 0 – 37 150 37 150 – 74 300 74 300 – 120 796 120 796 and over 7.70 12.50 13.30 9.80 13.80 16.70 8.79 14.95 16.67 17.50 21.00 9.10 12.10 12.40 14.30 0 – 37 774 37 774 – 75 550 75 550 – and over 5.05 9.15 11.16 0 – 31 000 31 000 – 67 000 67 000 and over 0 – 40 919 40 919 – 116 911 116 911 and over All income 0 – 36 146 36 146 – 72 293 72 293 – 83 001 83 001 – 100 787 100 787 and over 10.80 12.75 17.40 11.00 13.00 15.00 10.00 5.06 7.70 10.50 12.29 14.70 10 20 – 56 0 – 31 278 31 278 – 62 556 62 556 and over 0 – 31 984 31 984 – 63 969 63 969 – and over 0 – 29 590 29 590 – 59 180 59 180 -93 000 93 000 – 150 000 150 000 and over 0 – 36 421 36 421 – 72 843 72 844 – 118 427 118 427 and over 7.70 12.65 14.40 9.80 13.80 16.70 8.79 14.95 16.67 17.50 21.00 9.30 12.50 13.30 14.30 0 – 37 106 37 106 – 74 214 74 214 – and over 5.05 9.15 11.16 0 – 31 000 32 000 – 67 000 67 000 and over 0 – 40 354 40 354 – 115 297 115 297 and over All income 0 – 35 859 35 859 – 71 719 71 719 – 82 342 82 342 – 99 987 99 987 and over 10.80 12.75 17.40 11.00 13.00 15.00 10.00 5.06 7.70 10.50 12.29 14.70 10 20 – 56 26 Quebec** 0 – 39 060 39 060 – 78 120 78 120 and over 0 – 38 570 38 570 – 77 140 77 140 and over 16.00 20.00 24.00 2009 (1) Province 2008 (2) Taxable income 0 – 31 061 31 061 – 62 121 62 121 and over (3) Rate 7.70 12.80 15.50 Prince Edward Island 0 – 31 984 31 984 – 63 969 63 969 – and over 9.80 13.80 16.70 Nova Scotia 0 – 29 590 29 590 – 59 180 59 180 -93 000 93 000 and over 8.79 14.95 16.67 17.50 New Brunswick 0 – 35 707 35 707 – 71 415 71 415 – 116 105 116 105 and over 9.65 14.50 16.00 17.00 Ontario 0 – 36 848 36 848 – 73 698 73 698 – and over 6.05 9.15 11.16 Manitoba 0 – 31 000 31 000 – 67 000 67 000 and over 10.80 12.75 17.40 Saskatchewan 0 – 40 113 40 113 – 114 610 114 610 and over 11.00 13.00 15.00 All income 0 – 35 716 35 716 – 71 433 71 433 – 82 014 82 014 – 99 588 99 588 and over 0 – 38 385 38 385 – 76 770 76 770 and over 10.00 5.06 7.70 10.50 12.29 14.70 16.00 20.00 24.00 Newfoundland Alberta British Columbia Quebec** 16.00 20.00 24.00 (4) Surtax 10 10 20 – 56 (5) Taxable income 0 – 30 215 30 215 – 60 429 60 429 and over 0 – 31 984 31 984 – 63 969 63 969 – and over 0 – 29 590 29 590 – 59 180 59 180 -93 000 93 000 and over 0 – 34 836 34 836 – 69 673 69 673 – 113 273 113 273 and over 0 – 36 020 36 020 – 72 041 72 041 – and over 0 – 30 544 30 544 – 66 000 66 000 and over 0 – 39 135 39 135 – 111 814 111 814 and over All income 0 – 35 016 35 016 – 70 033 70 033– 80 406 80 406 – 97 636 97 636 and over 0 – 37 500 37 500 – 75 000 75 000 and over 2007 (6) Rate 8.20 13.30 16.00 9.80 13.80 16.70 10 8.79 14.95 16.67 17.50 10 10.12 15.48 16.80 17.95 6.05 9.15 11.16 20 – 56 10.90 12.75 17.40 11.00 13.00 15.00 10.00 5.24 7.98 10.50 12.29 14.70 16.00 20.00 24.00 2006 (1) (2) (3) (4) (5) (6) Province Taxable income Rate Surtax Taxable income Rate Newfoundland 0 – 29 886 29 886 – 59 772 59 772 and over (7) Surtax 9.64 14.98 17.26 4.5 0 – 29 590 29 590 – 59 180 59 180 and over 10.57 16.16 18.02 (7) Surta x 9 27 Prince Edward Island Nova Scotia New Brunswick Ontario Manitoba Saskatchewan Alberta British Columbia Quebec** 0 – 31 369 31 369 – 62 739 62 739 and over 0 – 29 590 29 590 – 59 180 59 180 -93 000 93 000 and over 0 – 34 186 34 186 – 68 374 68 374 – 111 161 111 161 and over 9.80 13.80 16.70 8.79 14.95 16.67 17.50 10.12 15.48 16.80 17.95 0 – 35 488 35 488 – 70 976 70 976 – and over 6.05 9.15 11.16 0 – 30 544 30 544 – 65 000 65 000 and over 0 – 38 405 38 405 – 109 729 109 729 and over All income 0 – 34 397 34 397 – 68 794 68 794 – 78 984 78 984 – 95 909 95 909 and over 0 – 29 290 29 290 – 58 595 58 595 and over 10.90 13.00 17.40 11.00 13.00 15.00 10.00 5.70 8.65 11.10 13.00 14.70 16.00 20.00 24.00 10 10 20 – 56 0 – 30 754 30 754 – 61 509 61 509 and over 0 – 29 590 29 590 – 59 180 59 180 -93 000 93 000 and over 0 – 33 450 33 450 – 66 902 66 902 – 108 768 108 768 and over 9.80 13.80 16.70 8.79 14.95 16.67 17.50 9.68 14.82 16.52 17.84 0 – 34 758 34 758 – 69 517 69 517 – and over 6.05 9.15 11.16 0 – 30 544 30 544 – 65 000 65 000 and over 0 – 37 579 37 579 – 107 367 107 367and over All income 0 – 33 755 33 755 – 67 511 67 511 -77 511 77 511 – 94 121 94 121 and over 0 – 28 710 28 710 – 57 430 57 430 and over 10.90 13.50 17.40 11.00 13.00 15.00 10.00 6.05 9.15 11.70 13.70 14.70 16.00 20.00 24.00 2005 (1) Province Newfoundland Prince Edward Island Nova Scotia New Brunswick Ontario Manitoba Saskatchewan Alberta British Columbia (2) Taxable income 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 30 754 30 754 – 61 509 61 509 – and over 0 – 29 590 29 590 – 59 180 59 180 -93 000 93 000 and over 0 – 32 730 32 730– 65 462 65 462 – 106 427 106 427 and over (3) Rate 10.57 16.16 18.02 9.80 13.80 16.70 8.79 14.95 16.67 17.50 9.68 14.82 16.52 17.84 0 – 34 010 34 010 – 68 020 68 020 – and over 6.05 9.15 11.16 0 – 30 544 30 544 – 65 000 65 000 and over 0 – 36 770 36 770 – 105 056 105 056 and over All income 0 – 33 061 33 061 – 66 123 10.90 14.00 17.40 11.00 13.00 15.00 10.00 6.05 9.15 10 10 20 – 56 2004 (4) Surtax 9 10 10 20 – 56 (5) Taxable income 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 30 754 30 754 – 61 509 61 509 and over 0 – 29 590 29 590 – 59 180 59 180 -93 000 93 000 and over 0 – 32 183 32 183 – 64 368 64 368 – 104 648 104 648 and over (6) Rate 10.57 16.16 18.02 9.80 13.80 16.70 8.79 14.95 16.67 17.50 9.68 14.82 16.52 17.84 0 – 33 375 33 375 - 66 752 66 752 – and over 6.05 9.15 11.16 0 – 30 544 30 544 – 65 000 65 000 and over 0 – 36 155 36 155 – 103 300 103 300 and over All income 0 – 32 476 32 476 – 64 954 10.90 14.00 17.40 11.00 13.00 15.00 10.00 6.05 9.15 (7) Surtax 9 10 10 20 – 56 28 Quebec** 66 123 – 75 917 75 917 – 92 185 92 185 and over 0 – 28 030 28 030 – 56 070 56 070 and over 11.70 13.70 14.70 16.00 20.00 24.00 64 954 - 74 575 75 575 – 90 555 90 555 and over 0 – 27 635 27 635 – 55 280 55 280 and over 11.70 13.70 14.70 16.00 20.00 24.00 2003 (1) Province Newfoundland Prince Edward Island Nova Scotia New Brunswick Ontario Manitoba Saskatchewan Alberta British Columbia Quebec** (2) Taxable income 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 30 754 30 754 – 61 509 61 509 – and over 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 32 183 32 183 – 64 368 64 368 – 104 648 104 648 and over (3) Rate 10.57 16.16 18.02 9.80 13.80 16.70 9.77 14.95 16.67 9.68 14.82 16.52 17.84 0 – 32 435 32 435 – 64 871 64 871 – and over 6.05 9.15 11.16 0 – 30 544 30 544 – 65 000 65 000 and over 0 – 35 000 35 000 – 100 000 100 000 and over 13 525 and over 0 – 31 653 31 653 – 63 308 63 308 – 72 685 72 685 – 88 260 88 260 and over 0 – 27 095 27 095 – 54 195 54 195 and over 10.90 14.90 17.40 11.00 13.00 15.00 10.00 6.05 9.15 11.70 13.70 14.70 16.00 20.00 24.00 2002 (4) Surtax 9 10 10 20 – 56 (5) Taxable income 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 30 754 30 754 – 61 509 61 509 – and over 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 31 677 31 677 – 63 354 63 354 - 103 000 103 000 and over (6) Rate 10.57 16.16 18.02 9.80 13.80 16.70 9.77 14.95 16.67 9.68 14.82 16.52 17.84 0 – 31 893 31 893 – 63 786 63 786 – and over 6.05 9.15 11.16 0 – 30 544 30 544 – 65 000 65 000 and over 0 – 30 000 30 000 – 60 000 60 000 and over 13 339 and over 0 – 31 124 31 124 – 62 249 62 249 - 71 470 71 470 – 86 785 86 785 and over 0 – 26 700 26 700 – 53 405 53 405 and over 10.90 15.40 17.40 11.25 13.25 15.50 10.00 6.05 9.15 11.70 13.70 14.70 16.00 20.00 24.00 2001 (1) Province Newfoundland* Prince Edward Island Nova Scotia New Brunswick Ontario (2) Taxable income 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 30 754 30 – 61 509 61 509 – and over 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 30 754 30 754 – 61 509 61 509 – 100 000 100 000 and over 0 – 30 814 30 814 – 61 629 (3) Rate 10.57 16.16 18.02 9.80 13.80 16.70 9.77 14.95 16.67 9.68 14.82 16.52 17.84 6.16 9.22 (7) Surtax 9 10 10 20 – 56 2000 (4) Surtax 9 10 10 (5) Taxable income 0 –29,590 29,590 – 59 180 59 180 and over 0 – 30 004 30 004 – 60 009 60 009 – and over 0 – 29 590 29 590 – 59 180 59 180 and over (6) Rate 10.54 16.12 17.98 9.80 13.80 16.70 9.77 14.95 16.67 0 – 29 590 29 590 – 59 180 59 180 and over 9.94 15.21 16.96 0 – 30 004 30 004 – 60 009 6.37 9.62 (7) Surtax 16 10 10 8 29 Manitoba Saskatchewan* Alberta* British Columbia Quebec** 61 629 – and over 11.16 0 – 30 544 30 544 – 61 089 61 089 and over 0 – 30 000 30 000 – 60 000 60 000 and over 10.90 16.20 17.40 11.50 13.50 16.00 12 900 and over 10.00 0 – 30 484 30 484 – 60 969 60 969 – 70 000 70 000 – 85 000 85 000 and over 0 – 26 000 26 000 – 52 000 52 000 and over 7.30 10.50 13.70 15.70 16.70 17.00 21.25 24.50 20 – 56 60 009 – and over 11.16 0 – 29 590 29 590 – 59 180 59 180 and over 0 – 30 000 30 000 – 60 000 60 000 and over 0 – 30 004 30 004 – 60 009 60 009 and up 8.00 12.22 13.63 8.16 12.00 13.92 7.48 11.00 12.76 0 – 30 004 30 004 – 60 009 60 009 and over 8.40 12.40 14.35 0 – 26 000 26 000 – 52 000 52 000 and over 19.00 22.50 25.00 20 – 56 * These provinces have provincial tax rates as a per cent of Basic Federal Tax in 2000. ** In Quebec all taxpayers receive a Quebec Abatement. The abatement consists of a reduction of 16.5 per cent of federal personal income tax. Various provinces provide tax relief to low-income earners in the form of targeted tax reductions and some provinces levy surtaxes, which primarily affect high-income earners. The rates in the columns 4 and 7 are expressed as a percentage of sub-central government tax rates. I.2. DENMARK The representative sub-central government tax rate is an average of municipal and regional rates. From 2007 the regions no longer collects taxes, and the representative sub-central government tax rate is then an average of municipal rates. I.2. FINLAND The representative sub-central government tax rate is an weighted average of municipal rates. A standard deduction for work-related expenses equal to the amount of wage or salary, with a maximum amount of EUR 620 is granted. An earned income tax allowance is granted municipal taxation. The allowance is calculated on the basis of taxpayer’s income from work. The allowance amounts to 51 per cent of income between EUR 2 500 and EUR 7 230, and 28 per cent of the income exceeding EUR 7 230, until it reaches its maximum of EUR 3 570. The amount of the allowance is reduced by 4.5 per cent of the earned income minus work related expenses exceeding EUR 14 000. A basic tax allowance is granted in municipal taxation on the basis of taxable income remaining after the other allowances have been subtracted. The maximum amount, EUR 2 880, is reduced by 20 per cent of the income exceeding EUR 2 200. I.2. ICELAND The representative sub-central government tax rate is an average of municipal rates. 30 I.2. ITALY These surcharges are due only by taxpayers who actually pay the Personal Income Tax (IRPEF). Representative sub-central rate The representative sub-central government tax rates are: Year 1998 1999 2000 2001 2002 2003 2006 2007 2008 2009 2010 2011 2012 Regional surcharge tax (Lazio) 0.5% 0.5% 0.9% 0.9% 0.9% 0.9% 1.4% 1.4% 1.4% 1.4% 1.7% 1.7% 1.73% Local surcharge tax (Rome) ----0.2% 0.2% 0.2% 0.5% 0.5% 0.5% 0.5% 0.9% 0.9% Regional surcharge tax This surcharge tax was introduced in 1997. The tax may be levied by each region on resident taxpayers’ total taxable income at a discretionary rate included in a given range. As from the year 2000 this range was 0.9% - 1.4%. Law Decree 201/2011 (later converted in Law 214/211) increased the basic regional surcharge tax rate from 0.9% to 1.23% (the legislation was retroactive, thus applied also for 2011): since then, the new basic range is 1.23% - 1.73%. For a group of Regions (see the Table below), the regional surcharge tax rate was further increased of 0.30% (starting from the biennium 2011/2012) due to regional budget deficit (bringing the maximum rate applied up to 2.03%). In addition to this, the Spending Review Decree advanced from 2014 to 2013 the possibility to apply a further increase of 0.6% in the Regions with persistent health budget deficit. Regional Surcharge Tax Rates For 2011/2012 in Lazio the Regional surcharge tax rate was 1.73%, due to: the increase of the basic regional surcharge tax rate from 0.9% to 1.23% and the additional charge of 0.50% applied to balance the Regional health budget deficit. Taking into account the possibility introduced by the Spending Review Decree (see above) the PIT tax rate of 1.73% applied in Lazio could be further increased up to 2.33%. Regional Surcharge Tax Rates Region Abruzzo Basilicata Bolzano 2013 Taxable income P.I.T. tax base P.I.T. tax base P.I.T. tax base Note: the regional surcharge tax is not levied on: Taxpayers earning a taxable income up to 15.000 Rate 1.73% 1.23% 1.23% 31 euros Taxpayers earning a taxable income up to 70.000, with dependent children, can benefit from a tax credit (not refundable) of € 252 for each child P.I.T. tax base P.I.T. tax base 0 15 000 0 20 000 0 25 000 More than 25 000 Note: For each income class, a single tax rate is always applied on the total amount of income 0 15 000 Note: For each income class, a single tax rate is always applied on the total amount of income P.I.T. tax base 0 20 000 More than 20 000 Notes: Each surcharge tax rate of is always applied on the total amount of income; For taxpayers with at least four dependent children, the regional surcharge tax is levied at a rate of 1.23%; For incomes between 20,000.01 and 20,101.76 the amount of tax due, determined using the rate of 1.734% is reduced by a corresponding amount which is obtained multiplying the coefficient 0.9827 for the difference between 20,101.76 euros and the amount of taxable income RV1: Calabria Campania Emilia Romagna Friuli Venezia Giulia Lazio Liguria 2.03% 2.03% 1.43% 1.53% 1.63% 1.73% 0.70% 1.23% 1,73% 1.23% 1.73% RV 1*1.73 0.9827 * 20 ,101 .76 RV 1 100 Lombardia Marche Molise Piemonte Puglia Sardegna Sicilia Toscana 0 15 000,01 28 000 0 15 000.01 28 000.01 55 000.01 More than 75 000 P.I.T. tax base 0 0 15 000 28 000 15 000 28 000 55 000 75 000 15 000 22 000 1.23% 1.58% 1,73% 1.23% 1.53% 1.70% 1.72% 1.73% 2.03% 1.23% 1.53% More than 22 000 Note: For each income class, a single tax rate is always applied on the total amount of income 1.73% 0 15,000.01 More than 28 000 P.I.T. tax base P.I.T. tax base 0 1.33% 1.43% 1,73% 1.23% 1.73% 1.43% 15,000 28 000 28 000 32 Trento 28 000.01 More than 55 000 P.I.T. tax base 0 More than 15 000 55 000 15 000 Umbria Valle d'Aosta Veneto Note: For each income class, a single tax rate is always applied on the total amount of income P.I.T. tax base P.I.T. tax base 1.68% 1.73 1.23% 1.23% 1.43% 1.23% 1.23% Local surcharge tax This surcharge tax was introduced in 1999. The tax may be levied by each local government at an initial rate that cannot exceed 0.2%. If the tax is levied, the local government can increase the initial rate, on a yearly basis, up to a maximum of 0.5%. For the city of Rome, the local surcharge tax is levied at an increased rate of 0.9% (higher than the maximum tax rate), due to municipal budget deficit. I.2. KOREA A uniform sub-central government tax rate of 10 per cent is used as a representative rate. The local government can adjust the rate between a lower limit of 5 per cent and an upper limit of 15 per cent. However, in practice all use the 10 per cent rate. I.2. NORWAY Although municipalities and regions are free to use reduced rates, in practice all use the maximum applicable rate - which is therefore also a representative rate. Personal income (i.e. ordinary income) is taxed with a 28 per cent flat rate in most of the country. Ordinary income includes all income (e.g. from labour, capital and pensions) less allowances. The revenue from the personal income tax on ordinary income is split between three levels of government: central, state and local. The split is decided upon by the Parliament as part of the National Budget. The state and local government tax rate is therefore the state and local government revenue share of tax on ordinary income. As mentioned, state and local governments may in principle reduce the local tax rate to a lower level, but in practice all use the maximum rates. The personal income tax rate on ordinary income is the same as the corporate tax rate. Any change in the rate will thus apply for both corporate and personal income tax. I.2. PORTUGAL As from 1999, special reduced rates apply in the case of residents in the Azores Autonomous Region (where the national rates are multiplied by 0.80) and as from 2001 in the Madeira Autonomous Region. I.2. SPAIN Until 2002, the Autonomous regions had the possibility of modifying their share in the income tax liability up to an amount of 20% by changing the regional tax schedule set up by central government, 33 keeping a progressive rate structure. As of 2003, the 20% restriction was abolished and the Autonomous regions are liable to keep a progressive rate schedule with the same number of tax brackets as the central government. Different types of income are pooled and offset according to its source, and are classified in two parts: the general income tax base and the saving income tax base Since 2011, the Autonomous regions are liable to set up their own personal income tax schedule to tax the general income tax base. Next table shows the most common tax rates schedule applied by regional governments to the general tax base. Net tax base Up to € 0.00 17,707.20 33,007.20 53,407.20 Gross amount due € 0.00 2,124.86 4,266.86 8,040.86 Rest of tax base Up to € 17,707.20 15,300.00 20,400.00 above Tax rate % 12.00 14.00 18.50 21.50 The savings tax base is subject to the following tax rates: Up to € 6 000 € 6 001 and over 9.5% 10.50% I.2. SWEDEN The representative sub-central government tax rate is an average of municipal rates. I.2. SWITZERLAND Representative sub-central rate: City of Zurich in the canton of Zurich. Minimum sub-central rate: City of Zug in the canton of Zug. Maximum sub-central rate: Delémont in the canton of Jura. The calculations do not take into account the church tax. I.2. UNITED STATES The representative sub-central state rate is a weighted average state marginal income tax rate on wages provided by the National Bureau of Economic Research (www.nber.org). Most states that impose personal income taxes allow personal allowances. The amount of those allowances varies. Seven states (and many localities) do not impose personal income tax. For 2005 through 2007, the maximum sub-central rate applies to California where the largest city, Los Angeles, does not impose personal income tax. For 2001 through 2004, the maximum sub-central state rate applies to Rhode Island where the largest city, Providence, does not impose personal income tax. For 2000, the maximum sub-central rate applies to California where the largest city, Los Angeles, does not impose personal income tax 34 The taxing wages sub-central rate is for Detroit, Michigan. Michigan allowed a tax credit for city income taxes paid through 2011. The tax credit was 20 per cent of city income taxes of $100 or less, 10 per cent of city income taxes of $101 through $150 and 5 per cent for city income taxes of $151 or more. The maximum credit was $10,000. 35 Part I, Table 3 I.3. CANADA Rates administered in the largest city in Canada, Toronto, located in province of Ontario. I.3. SPAIN Since 2007, capital gains form part of the taxpayer’s savings tax base, and are subject to a single flat tax rate of 18% (11.1% for central government, and 6.9% for the regions). For tax years 2012 and 2013, following tax rates apply: Central Government tax rate 11,50% Regional Government tax rate 9,50% 21,00% From € 6 000 up to € 24 000 14,50% 10,50% 25.00% Over € 24 000 16,50% 10,50% 27.00% Up to € 6 000 Total Capital gains with a holding period above one year were taxed (until 2006) at a flat tax rate of 15% (9.06% for central government, and 5.94 % for the regions) as of 2003. In previous years the applied rate was 18% (12.06% for central government, and 5.94% for the regions). I.3. SWITZERLAND 1) The sub-central (cantonal) personal income tax rates in Zürich (most populated city) and thresholds for single people without children for 2013, are: Rate per cent 0 2 3 4 5 6 7 8 9 10 11 12 13 2) Ceiling (SFR) 6 700 11 400 16 100 23 700 33 000 43 700 56 100 73 000 105 500 137 700 188 700 254 900 over 254 900 The sub-central (cantonal) personal income tax rates in Zürich (most populated city) and thresholds for married couples and singles with children for 2013: Rate per cent 0 Ceiling (SFR) 13 500 36 2 3 4 5 6 7 8 9 10 11 12 13 19 600 27 300 36 700 47 400 61 300 92 100 122 900 169 300 224 700 284 800 354 100 over 354 100 Married couples are taxed jointly. PART II. TAXATION OF CORPORATE AND CAPITAL INCOME Part II, Table 1 II.1. BELGIUM The effective CIT rate can be substantially reduced by an allowance for corporate equity (ACE). The amount of this allowance is neither related to the behaviour nor to the results of the company, but depends only upon the amount of qualifying corporate equity and the yield on long term government bonds. There is however an upper limit. The original upper limit (of 6.5 % for non-SMEs) was first temporarily reduced to 3.8% in 2010 and 2011 and then permanently lowed to 3% from 2012 onwards. The effectively applied ACE-rates are listed in the table below. Stricter carry forward rules concerning unused ACE-deductible amounts were implemented from 2013 onwards. Notional interest rate (ACE-rate) Non-SMEs Small and medium enterprises (SMEs) 2006 2007 2008 2009 2010 2011 2012 2013 3.442% 3.781% 4.307% 4.473% 3.8% 3.425% 3% 2.742% 3.942% 4.281% 4.807% 4.973% 4.3% 3.925% 3.5% 3.242% The lower the return on equity before tax, the lower the effective tax rate due to this allowance for corporate equity. E.g. the effective tax rate is only half the nominal tax rate when the return on equity before tax is twice the notional interest rate. The following table illustrates the impact of the ACE on the effective tax rate when the gross return on equity equals respectively 2, 3 or 4 times the notional interest rate. non-SMEs 2013 Gross return on equity (gROE) gROE / ACE-rate without ACE gROE = 2 ACErate gROE = 3 ACErate gROE = 4 ACErate 5.484 5.484 8.226 10.968 2 2 3 4 37 ACE-rate 2013 Taxbase Nominal CIT rate CIT Net profit Effective CIT rate 0 2.742 2.742 2.742 5.484 33,99% 2,328 4,522 33.990% 2.742 33,99% 0.932 4.552 16.995% 5.484 33,99% 1.864 6.362 22.660% 8.226 33,99% 2.796 8.172 25.493% II.1. CANADA The representative sub-central government tax rate is an average of provincial corporate income tax rates, weighted by the provincial distribution of the federal corporate taxable income. A federal surtax increased the general federal corporate income tax rate by 1.12 per cent between 1995 and 2007. Budget 2006 eliminated this surtax for all corporations as of January 1, 2008. II.1. CHILE Business profits made by individuals or legal entities resident or domiciled in Chile are taxed via the First Category Tax (FCT) levied at a tax rate of 20%. It applies to profits from any commercial activity whether the enterprise is a legal entity, a branch, a permanent establishment of a foreign company, sole proprietorship or an individual. The tax base is defined as total income less the costs and expenses required to produce it taking into account inflation adjustments. A loss incurred may be carried back and/or forward and deducted against profits without time limit.- It may also be offset against previous retained earnings in a kind of carry-back. Individuals and legal entities that are not resident or domiciled in Chile are generally taxed on any income derived from Chilean sources at a standard tax rate of 35% (lower rates apply for some types of income and are available under double taxation agreements). II.1. FRANCE The rates in Table II.1 include surcharges, but do not include the local business tax (Contribution économique territoriale, a new tax replacing the former Taxe professionnelle from January 1st 2010), the turnover based solidarity tax (Contribution de Sociale de Solidarité sur les Sociétés), the 5% temporary surtax applies to the standard corporate income tax liability for large company with a turnover exceeding € 250 million, or the 3 % additional contribution on distributed profits.The Contribution Sociale de Solidarité sur les Sociétés is levied at a rate of 0.16% (0.13% plus a surcharge of 0.03%) of the turnover of companies, excluding VAT. It is deductible for income tax purposes. The standard corporate income tax rate is 33.33%. It is increased by a 3,3% surcharge (Contribution Sociale sur les Bénéfices) for companies with a turnover of at least EUR 7,630,000 on the part of their liable tax payments in excess of EUR 763,000 - resulting in an effective tax rate of 34.43% for companies that have profits above EUR 2,289,000. Starting in 2010, the local business tax (taxe professionelle) is being abolished and replaced with a new local economic contribution, the contribution économique territoriale (CET). The CET is composed of two separate taxes, the corporate property contribution (cotisation foncière des entreprises, or CFE) and the contribution for value added (cotisation sur la valeur ajoutée des entreprises, or CVAE). As previously, this tax applies to branches and subsidiaries established in France. The tax is capped at 3% of the company’s value added (the former local business tax was capped at 3.5% of value added). 38 The CFE is based on the value of owned or leased office premises. The productive investments are no longer taxed, as it was with the previous local business tax, i.e. equipment and movable property which include machines, tools, movable property and equipment. The CFE is calculated by multiplying the cadastral value of the premises by a certain coefficient, assessed annually by the local authorities. The local authorities also set the minimum contribution payable by the companies in their jurisdiction. The contribution for value added by businesses (CVAE) is assessed on the value added companies realize during the previous calendar year or the last 12-month financial year if this does not coincide with the calendar year. It applies to firms concerned by the CFE with turnover exceeding EUR 152,500. Only companies with annual pre-tax turnover of over EUR 500,000 must pay the CVAE, but all have to declare the value added created during the fiscal year. The CVAE rate is theoretically 1.5% for companies with an annual pre-tax turnover of over EUR 50 million. Below this amount, companies are subject to a reduced CVAE rate, adjusted according to the level of the company turnover. The assessed value added is itself capped, depending on the case, at 80% or 85% of turnover (depending on whether the company’s turnover is below or above EUR7,600,000). II.1. GERMANY The representative sub-central government corporate income tax rate is for Berlin. In the years between 2000 and 2007 this rate was 0.05 (general rate) * 410 per cent (local “Hebesatz”) = 20.5 per cent. As the local business tax was deductible from its own base, the effective rate was 20.5 / 120.5 = 17 per cent. This implies that the effective central government corporate income tax rate in 2007 was 26.375 per cent * (1-0.17) = 21.9 per cent. The combined corporate income tax rate in 2007 was therefore 38.9 per cent, as it also was in 2006, 2005, 2004, 2002 and 2001. In 2003, the effective central government corporate income tax rate was 27.96 per cent * (1-0.17) = 23.2 per cent due to a temporary increase in the tax rate in order to finance the repair of the damages caused by the major floods in 2002. The combined corporate income tax rate in 2003 was therefore 40,2 per cent. In 2000, the effective central government corporate income tax rate was 42.2 per cent * (1-0.17) = 35 per cent. The combined corporate income tax rate was therefore 52 per cent. With the Corporate Tax Reform in 2008 the representative sub-central government corporate income tax rate was changed to 14.35 per cent (0.035 general rate * 410 per cent “Hebesatz”). Local business tax is no longer deductible from its own base. The central government corporate income tax rate was reduced to 15 per cent. The combined corporate income tax rate is now at a level of 30.18 per cent. II.1. GREECE In general, the legal form of the company determines the applicable tax rate. For additional information on data before the year 2012, see the explanatory notes for table II.4. Corporate Taxation Under the Income Tax Code (2238/1994), as recently amended with the law 4110/2013, the Basic Tax Rate for corporate income earned in 2013 is 26%. The rate is decreased by 40% (so the rate is 60 x 26% = 15,60%) for income earned from business activities in Greek islands with less than 3100 inhabitants. 39 An additional tax of 3% is levied on gross income derived from immovable property but this tax cannot exceed the tax calculated on the company’s income. Legal entities subject to corporate income tax include: a. corporations (SAs), b. limited liability companies (LLCs), c. or not, d. state and municipal undertakings and profit-making enterprises, whether they have legal form cooperatives and associations, e. foreign undertakings operating in Greece, in whatever company form, and any other organizations engaged in business activities, foreign f. non-profit-making Greek and foreign legal persons governed by public or private law, including foundations of all kinds (only for income derived by hiring out immovable property and income from mobile assets) . g) private capital companies (PCC) (a new company form introduced with art. 116 of law 4072/2012). The Law provides certain tax-exemptions. For instance, the Greek State is fully exempt from taxation, as well as Municipalities, Universities, Hospitals etc., which are only liable to tax in respect of income from transferable securities. A special tax regime (tonnage tax) applies for the operation of ships under Greek flag. Additionally, tax exemption applies in any income derived in Greece by foreign legal or physical persons if this is foreseeable under special provisions of a bilateral Convention of Double Taxation or a Multirateral International Convention (NATO, U.N., Diplomatic Missions etc. Furthermore, from 2013 onwards, Holy Churches, Monasteries etc. are liable to tax in respect of income from immovable property, - same as all the non profit entities, at a flat rate of 26%, which exhausts their tax liability. Under the tax law 4110 - enacted in 23 January 2013, distributed profits (approved by the general meetings as of 1.1.2014 onwards) by Corporations (SAs), in the form of dividends, Board and Directors fees, additional compensation of directors and employees other than wages, as well as interim dividend payments are subject to a 10% withholding tax - which exhausts the relevant income tax liability of the recipients. In case of a parent-subsidiary relationship, dividend payments and profit distributions paid by subsidiary permanent establishment companies to their parent companies established in another EU Member-State shall be exempt from withholding tax provided that the conditions set forth in art. 11 of Law 2578/1998 are fulfilled (application of the EU Parent-Subsidiary Directive). Partnerships, joint ventures - other legal entities 40 2000-2012) TAX RATES FOR LEGAL ENTITIES (except for those subject to corporate income taxation) Type of legal person Limited partnership (EE) & Unlimited general partnership (OE), Civil law communities Joint ventures, Civil companies, , Silent partnerships and Participation companies Legal services companies of L.518/89, Notary companies of L.284/93 1/1/2000 – 31/12/2004 1/1/200531/12/2005 1/1/200631/12/2006 1/1/200731/12/2007 1/1/2008 31/12/2009 1/1/201031/12/12 24% 22% 20% 20% 20% 35% 32% 29% 25% 25% 25% 25% 25% 25% 25% 25% 25% 25% . Partnerships under the Greek Law may be either general or limited partnerships. Under the so far applicable rules, the above mentioned tax rate of 20% was imposed on the profits relating to partners who were individuals, following the deduction of their entrepreneurial fee, whereas the profits corresponding to legal entities partners were taxed at a 25% rate. The Law 4110 enacted in 23 January 2013 brought significant changes to the tax regime of partnerships, civil law societies, silent partnerships, participation companies, joint-ventures, legal services and notary companies, which from 1/1/2013 onwards are taxed with the following tax schedule: Partnerships, joint ventures - other legal entities maintaining single entry accounting books (2013 onwards) Income bracket (€) 50.000 Tax rate (%) 26% Tax bracket (€) 13.000 Total amount of Income (€) 50.000 Tax (€) 13.000 41 Excess 33% For those entities which maintain double-entry books, their tax treatment is now aligned with that of corporations (SAs, LLCs and PCCs), which means that the entire amount of their net profits is taxable at the level of the entity (taxation at the level of the entrepreneur is abolished) at a flat rate of 26% , whereas a 10% withholding tax is imposed on distributed profits.The entrepreneurial fee received by the general partner is no longer taxed as personal income deriving from commercial enterprises. All the above rates are decreased by 40% for income earned from business activities in Greek islands with less than 3.100 inhabitants. II.1. HUNGARY The rates do not include a turnover-based local business tax. Local governments are entitled to levy a local business tax on corporations in their jurisdiction, which is generally levied on turnover less acquisition costs of goods sold, subcontractor fees, material costs and costs directly related to R&D activities. The maximum rate is 2 %, and the tax is deductible for income tax purposes and until 2009 an additional tax relief was applicable on it (in 2004: 25 %, in 2005: 50 %, and in the period of 2006-2009: 100 %). Some local governments grant exemptions for small businesses. The rates do not include the innovation tax as well. This tax is levied on the same basis as the local business tax. The innovation tax rate was 0.2 % in 2004, 0.25 % in 2005, and is 0.3 % from 2006. Small enterprises are exempted from this tax. As from 2007 credit institutions are obliged to pay 5 % surtax on interest income from loans associated with state subsidies. This tax is excluded from the table. As from 2009 corporations supplying energy products are obliged to pay a surtax of 8 % on the basis of (adjusted) profit before taxation. This tax is excluded from the table. In 2005 and 2006 credit institutions and financial enterprises were obliged to pay a special tax on their interest income (tax rate was 6 %) or on the profit before corporate income tax (tax rate was 8 %). This tax is excluded from the table. In the period of 1 September 2006-31 December 2009, taxpayers were obliged to pay a surtax of 4 % on the basis of (adjusted) profit before taxation. As from September 2010, financial corporations are obliged to pay a temporary crisis tax, the rate of which is to be halved in 2013 and abolished from 2014. Different rules have been applicable to institutions engaged in different activities.. A temporary sectoral crisis tax to be levied in years 2010-12 was introduced also for the energy, telecommunications and consumer goods retail sectors. The crisis tax is levied on the net sales turnover realized by corporations in the specific taxable sectors. The crisis tax is excluded from the table. II.1. ISRAEL The following table shows the historical tax rates for tax on the combination of wages and salaries and profits that the Financial Institutions pay in lieu of VAT. 42 Period 1 January 2000 -14 June 2002 15 June 2002- 29 February 2004 1 March 2004- 30 June 2006 1 July 2006- 30 June 2009 1 July 2009 – 31 Dec 2009 1 January 2010 – 31 Aug 2012 1 Sept 2012 Tax rate (percent) 17 18 17 15.5 16.5 16.0 17.0 II.1. ITALY Italian Local Income Tax – ILOR Law no.825 of 1971 introduced local income tax. This tax was applied: in the case of individuals wherever resident, on income accrued within the territory of the State, excluding income from employment calculated for personal income tax purposes; in the case of legal persons, on the overall net income calculated for the purposes of corporate income tax . Although initially the revenue was allocated to local authorities, starting from 1974 the income was included in the State budget and the tax was no longer considered as local. The tax was deductible for the purposes of personal income tax, while for the purposes of corporate income tax, it was deductible from 1971 to 1990, partially deductible in 1991 and non-deductible until its abolition in 1998. This tax was abolished with the introduction of IRAP (Regional Tax on Productive Activities). The Dual Income Tax (DIT) The Dual Income Tax (DIT) is a special regime for the taxation of business income introduced with legislative decree n. 446/1997 and aimed at creating incentives for companies to increase selfcapitalization thereby boosting economic activities. With the DIT, the taxable business income is divided into two segments: The first segment is an hypothetical return calculated by multiplying any qualifying increase in the net equity of the company by a nominal interest rate provided by the State, in excess of the net equity at the end of the taxable year which includes 30th September 1996. This income benefits from a reduced rate for personal income tax or corporate income tax (IRPEG or IRPEF), generally of 19% (7% for newly-listed companies). 43 The second segment, which is the difference between taxable business income and the amount included in the first segment, is subject to the standard tax rates. Anti-avoidance rules have been introduced in order to prevent the practice of multiplying the basis for calculating the DIT by introducing several times the same new investments. A special anti-avoidance regime has also been provided for in the case of groups of companies. The Super-DIT The so-called super-DIT regime, which was introduced with Legislative decree 18 January 2000 no. 9, extends the DIT benefit also to smaller enterprises which wish to be quoted on the Stock Exchange. It provides for even stronger incentives with a reduced tax rate which can be as low as to 7%. Art. 2, paragraph 1, letter a) of Legislative decree no.9 of 18th January 2000 provides that the qualifying increases in the net equity are multiplied by 1.2 for the taxable period following that which includes 30th September 1999, and by 1.4 for subsequent taxable periods. In each taxable period, however, the increases in the equity capital, as adjusted by the above factors, cannot go as far as creating a sort of “virtual” net worth, that is to say an amount exceeding the threshold of the total year-end equity capital of the company which appears in the financial statements. Moreover, this regime does not apply if the net equity of a quoted company at the end of the tax year preceding the relevant tax year exceeds € 258,228,450 before taking in account the profits for the tax year. The DIT incentives have been “frozen” at 30.06.2001; only those companies that had deliberated qualifying increases in net equity before 30.06.2001 have continued to benefit from DIT incentives until the introduction of the new Corporate Income Tax (IRES). Substitute tax on income from alienation and contributions of businesses, mergers, de-mergers and exchange of shares. In 1997 an optional taxation regime of capital gains derived from corporate reorganizations, such as alienation of businesses owned for at least three years, the alienation of qualified or associated participations if the participations were classified as fixed financial assets at least in the last three balance sheets, mergers and de-mergers. Such regime provided for the application of a substitute tax with a 27% rate replacing both corporate and local income taxes. The regime gave the option to pay the tax due in up to five equal annual instalments. This tax was abolished in 2004. The regional tax on production activities - IRAP In Italy the most relevant tax mix change concerned the introduction of the so-called IRAP in 1998, a regional tax on business activities paid by corporations and unincorporated entities which main characteristics is a wide tax base and a relative low tax rate. IRAP represents the basic source of revenue for the National Health System, nevertheless with its introduction other 6 taxes have been abolished, ILOR among others. IRAP is charged on the value of net production resulting from the business pursued within the region. The rate of tax is set at 4.25 % for tax payers generally but may be increased by up to one percentage point by individual regions. 44 The 2008 Budgetary Law has reduced the standard tax rate to 3.9% and in 2009 a deduction, from PIT and CIT, of IRAP concerning interests and labour costs (that is a 10% quota of IRAP paid in the previous year) has been introduced. Furthermore, a reduced tax rate of 1,90% is charged on taxpayers operating in the agricultural sector and on cooperatives of the fishing sector; various special IRAP regimes apply as well. Law Decree 98/2011 later introduced increased tax rate for banks (4.65%), insurance companies (5.90%) and concessionary companies outside the motorway sector (4.20%). As regards in detail IRAP standard tax rates, the standard tax rate of 3,9% can be reduced or augmented up to a maximum of 0,92%, plus an optional increase of 0,15% for the Regions with helth budget deficit. As a result, the actual range for standartd tax rates is 2,98%- 4,97% The following table confirms the widespread variation of IRAP standard tax rates applied among Regions (tax rates in the table are updated to 2012): Region Standard tax rate Abruzzo 4,60 % Basilicata 3,90 % Bolzano 2,98% Calabria 4,97 % Campania 4,97 % Emilia Romagna 3,90 % Friuli Venezia Giulia 3,90 % Lazio 4,82% Liguria 3,90% Lombardia 3,90% Marche 4,73% Molise 4,97% Piemonte 3,90 % Puglia 4,82% Sardegna 3,90% 45 Sicilia 4,82% Toscana 3,90% Trento 3,44% Umbria 3,90% Valle d’Aosta 2,98% Veneto 3,90% In addition to this, the Italian tax system provides a set of IRAP forfetary deductions concerning dependent workers hired with an open-end contract, dependent workers hired in disadvantaged Regions and taxpayers of minor dimensions1. Law Decree 201/2011 raised all these deductions, and also introduced the possibility, for Regions, to apply for a full deduction, from PIT and CIT tax liability, of IRAP concerning labour costs. Later Law 208/2012 deferred the increases of IRAP deductions until 2014. As a result, these are the IRAP deductions in force for 2012 and 2013: dependent workers hired with an open-end contract: 4,600 euros, increased up to 10,600 euros for women an people under 35 years old dependent workers hired with an open-end contract in a group of Regions (Abruzzo, Basilicata, Calabria, Campania, Molise, Puglia, Sardegna e Sicilia): 9,200 euros, increased up to 15,200 euros for women and people under 35 years old deductions for taxpayers of minor dimensions: Tax base (amount in euros) IRAP deductions (amount in euros) Up to 180,759.91 7,350 From 180,759.91 and up to 180,839.91 5,500 From 180,839.91 and up to 180,919.91 3,700 From 180,919.91 and up to 180,999.91 1,850 Starting from 2014, the IRAP deductions mentioned above will be augmented as follows: 1 There are some eceptions related to the Public Administration, banks, insurance companies and firms operating in the financial sector, firms operating under the system of legal concession, etc, 46 dependent workers hired with an open-end contract: 7,500 euros, increased up to 13,500 euros for women an people under 35 years old dependent workers hired with an open-end contract in a group of Regions (Abruzzo, Basilicata, Calabria, Campania, Molise, Puglia, Sardegna e Sicilia): 15,000 euros, increased up to 21,000 euros for women and people under 35 years old deductions for taxpayers of minor dimensions: Tax base (amount in euros) IRAP deductions (amount in euros) Up to 180,759.91 8,000 From 180,759.91 and up to 180,839.91 6,000 From 180,839.91 and up to 180,919.91 4,000 From 180,919.91 and up to 180,999.91 2,000 The new Corporate income tax - IRES At the end of the year 2003 the IRPEG, together with the DIT incentives, was abolished. As of 1 January 2004 a new corporate income tax, IRES, was introduced with a statutory tax rate of 33%. The 2008 Budgetary Law has cut the tax rate from 33% to 27.5%. The 2004 reform of corporate taxation provides for a general system of capital gains exemption with no deductibility of the corresponding capital losses. Starting from 2008, the exemption is granted on 95%, of the total amount of capital gains. Furthermore, the imputation method previously used to eliminate dividend double taxation has been replaced with the exemption method (dividends are exempted for up to 95% for taxpayers subject to IRES and up to 60% for taxpayers subject to IRPEF). For taxpayers subject to IRPEF dividends arising from non-qualified participations are taxed separately at a rate of 20%. Starting from 2008 dividends arising from qualified participations are exempt for up to 50.28% (previously the exemption was 60%). In the same year, 'thin capitalization' rules has been abolished as well as some depreciation allowances and anticipated depreciation and new rules has been introduced in order to limit the deduction of interest expenses: full deduction of interest expenses up to the value of interest revenues; possibility to deduct the interest expenses exceeding the amount of interest revenues up to 30% of Gross Operating Profit; possibility to increase with the unused portion of Gross Operating Profit of a given tax period, the Gross Operating Profit of the subsequent tax periods (starting from 2010). 47 Starting from 2004 group consolidation for tax purpose has been introduced, both at the domestic level and worldwide, on condition that the parent company controls at least 50% of the subsidiary. At domestic level the option for tax consolidation is bilateral and can be exercised by some or all the companies belonging to the group; the consolidated tax base is given by the algebraic sum of the taxable incomes of the consolidated companies regardless of the percentage of shareholding held by the parent company. The minimum period for tax consolidation is 3 years and the option can be renewed for a period of the same length. The option for worldwide consolidation can be exercised only by the parent company of the highest level and requires consolidation of all companies belonging to the group. The option cannot be exercised if one of the subsidiaries is resident in a tax haven or benefits from a privileged tax regime. The consolidated tax base is given by the algebraic sum of the percentage of taxable income of each consolidated company corresponding to the shareholding held by the parent company. The minimum period for tax consolidation is 5 years and the option can be renewed for a period of 3 years. In addition, corporations participated by other corporations (each with a shareholding of at least 10% and not higher than 50%) and limited liability companies with no more than 10 shareholders that are natural persons can impute pro-quota their taxable income to the shareholders (the company is 'transparent' for tax purposes). The so-called ‘Robin tax’ An additional CIT rate of 5.5% was introduced during 2008 charged on oil, gas and electricity industries in relation to extra profit generated from exceptional high oil prices. It is explicitly forbidden for those firms to shift the tax on prices, under the surveillance of the Energy Authority. Since 2009 the rate was increased to 6.5%. Law Decree 138/2011 further increased the rate from 6.5% to 10.5% for the tax periods from 2011 to 2013. The Robin tax is now charged also on companies that produce electricity through the use of renewable sources of energy. The new Allowance for Corporate Equity (ACE) system of taxation Starting from 1st January 2012, Italy introduced a variant on the Italian corporate income tax that is the allowance for corporate equity (ACE) system of taxation, now applied to new injections of equity funds in Italian enterprises (both in the form of money given by shareholders and as accumulated profits). According to the new system, firms are allowed to deduct a notional return on their new injections of equity, defined as the product of the amount of new equity funds (with reference to the equity stock at 31st December 2010), with a notional interest rate that, according to Italian rules, is equal to 3% for the years from 2011 to 2013 (after that term, the notional interest rate to be applied to the injections of new equity will be determined each year by the Ministry of Economy and Finance). II.1. LUXEMBOURG The representative sub-central government corporate income tax rate is for Luxembourg City. The rate is 0.03 (general rate) * 225 per cent (taux communal) = 6.75 per cent. 48 II.1. MEXICO Corporate Income Tax Table for the years 1981 to 1986: Taxable income Lower Limit (MXN) 0.01 2,000.01 3,500.01 5,000.01 8,000.01 11,000.01 14,000.01 20,000.01 26,000.01 32,000.01 38,000.01 50,000.01 62,000.01 74,000.01 86,000.01 100,000.01 150,000.01 200,000.01 300,000.01 400,000.01 500,000.01 Fixed Quota Upper Limit (MXN) (MXN) 2,000.00 3,500.00 5,000.00 8,000.00 11,000.00 14,000.00 20,000.00 26,000.00 32,000.00 38,000.00 50,000.00 62,000.00 74,000.00 86,000.00 100,000.00 150,000.00 200,000.00 300,000.00 400,000.00 500,000.00 And over 75.00 165.00 375.00 615.00 885.00 1,485.00 2,145.00 2,925.00 3,885.00 6,045.00 8,325.00 10,725.00 13,305.00 16,455.00 28,505.00 41,885.00 71,525.00 105,525.00 210,000.00 Tax on the amount in excess of lower limit (%) Exent 5.00 6.00 7.00 8.00 9.00 10.00 11.00 13.00 16.00 18.00 19.00 20.00 21.50 22.50 24.10 26.76 29.64 34.00 38.00 42.00 In 2000 and 2001, all firms could defer 5 per cent of their corporate income tax on reinvested profits. These profits were taxed at a 30 per cent rate; the deferred 5 per cent were paid when the profits were distributed. The corporate tax rate (30 per cent in 2013) is the same as the personal income tax rate on ordinary income, as a result of the integration of the CIT and PIT in the Mexican fiscal system. As from 2008, a minimum complementary tax to the income tax was introduced, the Business Flat Rate Tax or IETU by its Spanish sigla (the taxpayer only pays the excess of the IETU over his/her income tax). This tax substituted the Assets Tax and has a rate of 17.5%. The IETU taxes the income generated by the transfer of goods, the rendering of independent services and the granting of temporary use or enjoyment of goods, allowing the deduction of expenses corresponding to the purchase of goods, independent services or the temporary use or enjoyment of goods used in those activities, and the investments in fixed assets. Taxpayers’ can also obtain a credit for the taxed wages and salaries paid. II.1. NETHERLANDS Since 2000 the corporate tax rate has been gradually reduced from 35% to 25% in 2011. The basic tax rate applies to taxable income over € 60.000 in 2007, € 275.000 in 2008 and € 200.000 from 2009. . To taxable income below that limit a reduced rate of 20% applies. II.1. NORWAY The corporate tax rate (28 per cent) is the same as the personal income tax rate on ordinary income. 49 Any change in the rate will thus apply for both corporate and personal income tax. II.1. POLAND The payers of corporate income tax are taxed with flat rate tax. In recent years, the rate of this tax base has been gradually reduced from 40% in 1996 to 30% in 2000 as well as to 19% in 2004. This 19 % tax rate is still at present. The corporate income tax encompasses all revenue of legal persons, organisational units without the status of a legal person, with the exception of companies without the status of a legal person and tax capital groups, excluding revenue from: agricultural activity (except special sections of agricultural production), forest economy. The CIT Act exempts certain types of income from tax , e.g.: income received by taxpayers from governments of foreign countries, international organizations or international financial institutions etc., income from grants, subventions, subsidiary payments and other gratuitous performances received to cover costs or to refund expenses incurred in connection with receipt, direct payments applied within the Common Agricultural Policy of the European Union, income of taxpayers (not apply to State enterprises, cooperatives and companies) whose statutory aim is: scientific activity, technical research, supporting public projects in building roads and telecommunication networks and water supply system in rural areas, charity, health protection and social aid, religious practice – in the part designed for such purposes, income of churches legal persons or incomes of companies whose sole shareholders is a church legal person designed for the religious, charity, educational and on activities, income from school activity – in part designed for schools’ purpose. The corporate income tax is the central government tax but revenue from this tax is split between central government and local governments. II.1. SWITZERLAND In Switzerland, companies pay a tax on capital and a tax on profit. However, because the data in this table are limited to corporate income tax rates, effective tax rates for companies are computed here without factoring in the tax on capital. Calculation of the effective income tax rate therefore disregards the fact that the rate of tax on capital is deductible from the income tax. The nominal corporate tax rate (t c) is the sum of the nominal federal tax rate (tcf) and the cantonal (or regional) rate (tcr). The overall effective tax rate taking deductions into account (t’) is computed as follows: t’c= (tcf +tcr)/(1+tcf+tcr) = tc/(1+tc). The effective federal profit tax rate is thus t’cf = tcf(1-t’)= tcf/(1+tc). The effective regional profit tax rate is: t’cr= tcr(1t’)=tcr/(1+tc). The quantity tcr is computed by multiplying the base rate by M: tcr = base rate *M. The variable M is the sum of cantonal, communal and church multiples. In the case of companies, church taxes are included as businesses cannot avoid them. Information on rates excluding church taxes are included as comments in the table itself. II.1. UNITED STATES The federal income tax rate of 35 per cent generally applies to taxable income over $10 million. 50 The representative sub-central rate is a weighted average state corporate marginal income tax rates. It was calculated based on the methodology provided in King, Mervyn and Don Fullerton, eds., The Taxation of Income from Capital, Chicago: University of Chicago Press, 1984, p. 204. The weighted average rate is the sum for all states of the top corporate income tax rate for each state multiplied by the state’s share in personal income. Beginning in 2005 taxpayers are permitted a deduction for a portion of income from US production activities, which is phased in over six years. Beginning in 2010, the deduction is nine percent (three percent for 2005 and 2006 and six percent for 2007, 2008 and 2009) of the lesser of (1) qualified production activities, or (2) taxable income. The deduction is limited to 50 percent of wages paid by the employer. Part II, Table 2 II.2. AUSTRALIA Pooled Development Funds (PDF) Concessional taxation treatment is available to investment companies that are established and registered as Pooled Development Funds (PDFs). Income arising from investments in small-medium enterprises is taxed at 15 per cent and other income is taxed at 25 per cent. The PDF was closed to new registration from 21 June 2007. Although the PDF program has been replaced by an ‘early stage venture capital partnership’ (ESVCLP) investment vehicle, the program continues to operate for PDFs that were registered at the closure date of the program. II.2. BELGIUM Small business income Small business corporate tax rates income marginal year rate marginal threshold rate marginal threshold rate threshold 1977 33.00 not available bef 1978 33.00 not available bef 1979 33.00 not available bef 1980 33.00 not available bef 1981 33.00 not available bef 1982 33.00 1 000 000 1983 31.00 1 000 000 1984 31.00 1985 1986 3 600 000 40.00 14 400 000 bef 14 400 000 bef 3 600 000 47.50 1 000 000 3 600 000 not available bef 31.00 1 000 000 3 600 000 not available bef 31.00 1 000 000 3 600 000 not available bef 1987 30.00 1 000 000 3 600 000 not available bef 1988 30.00 1 000 000 3 600 000 not available bef 1989 30.00 1 000 000 3 600 000 not available 1990 29.00 1 000 000 37.00 3 600 000 43.00 14 800 000 bef 1991 28.00 1 000 000 36.00 3 600 000 41.00 13 000 000 bef 1992 28.00 1 000 000 36.00 3 600 000 41.00 13 000 000 bef bef 51 1993 28.84 (28.0) 1 000 000 37.08 (36) 3 600 000 42.23 (41) 13 000 000 bef 1994 28.84 (28.0) 1 000 000 37.08 (36) 3 600 000 42.23 (41) 13 000 000 bef 1995 28.84 (28.0) 1 000 000 37.08 (36) 3 600 000 42.23 (41) 13 000 000 bef 1996 28.84 (28.0) 1 000 000 37.08 (36) 3 600 000 42.23 (41) 13 000 000 bef 1997 28.84 (28.0) 1 000 000 37.08 (36) 3 600 000 42.23 (41) 13 000 000 bef 1998 28.84 (28.0) 1 000 000 37.08 (36) 3 600 000 42.23 (41) 13 000 000 bef 1999 28.84 (28.0) 1 000 000 37.08 (36) 3 600 000 42.23 (41) 13 000 000 bef 2000 28.84 (28.0) 1 000 000 37.08 (36) 3 600 000 42.23 (41) 13 000 000 bef 2001 28.84 (28.0) 25 000 37.08 (36) 89 500 42.23 (41) 323 750 euro 2002 28.84 (28.0) 25 000 37.08 (36) 89 500 42.23 (41) 323 750 euro 2003 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 euro 2004 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 euro 2005 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 euro 2006 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 euro 2007 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 Euro 2008 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 Euro 2009 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 Euro 2010 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 Euro 2011 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 Euro 2012 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 Euro 2013 24.98 (24.25) 25 000 31.93 (31) 90 000 35.535 (34.5) 322 500 Euro Reduced rates can be applied when the taxable profit does not exceed a threshold. Threshold starting from income year 2003: 322 500 euro. Taxable net profit in euros 0 – 25 000 25 000 – 90 000 90 000 – 322 500 322 500 and over Rate applicable to this bracket 24.25% 31% 34.50% 33% Rate applicable including 3% surtax 24.9775% 31.93% 35.535% 33.99% The lower the return on equity before tax, the lower the effective tax rate due to the allowance for corporate equity (ACE). The following table illustrates the impact of the ACE on the effective tax rate when the gross return on equity equals respectively 2, 3 or 4 times the notional interest rate and assuming that SMEs that qualify for reduced rates also qualify for the increased ACE-rate (3.942% in 2006, 4.281% in 2007, 4.807% in 2008, 4.973% in 2009, 4.3% in 2010, and 3.925% in 2011, 3.5% in 2012 and 3.242% in 2013). 52 SMEs 2011 without ACE gROE = 2 ACErate gROE = 3 ACE-rate gROE = 4 ACE-rate Gross return on equity (gROE) 6.484 6.484 9.726 12.968 gROE / ACE-rate ACE-rate 2011 Taxbase Nominal CIT rate CIT Net profit Effective CIT rate 2 0 6.484 2 3,242 3,242 3 3,242 6.484 4 3,242 9.726 33.99% 2,204 4.280 33.99% 1,102 5.382 33.99% 2,204 7.522 33.99% 3.306 9.662 33.99% 16.995% 22.66% 25.493% Threshold for 2002 and 2001: 323 750 euro. Taxable net profit 0 – 25 000 25 000 – 89 500 89 500 – 323 750 323 750 and over Rate applicable to this bracket 28% 36% 41% 39% Rate applicable including 3% surtax 28.84% 37.08% 42.23% 40.17% In order to qualify for these reduced rates, a company must fulfil a number of conditions. The company must not be an investment company and must not be part of a group to which belongs a co-ordination centre; Entitlement to the reduced rates is not granted to companies of which at least 50% of the shares are held by one or more other companies; At least one of the managers is granted a remuneration which, if it is less than a certain threshold, shall not be less than the company’s taxable income. The threshold increased from +/- 24 500 euros (until 2003), to 36 000 (starting from income year 2007); Threshold 2000 2001 2002 2003 2004 2005 2006 In euros 24 789.35 24 500 24 500 24 500 27 000 30 000 33 000 As from 2007 36 000 Except for certain recognized co-operative companies, entitlement to the reduced rates is also denied when the dividend payments exceeds 13% of equity capital effectively paid up at the beginning of the tax period. In order to qualify for the increased ACE-rate, the number of employees must be lower than 100 (annual average) and not more than one of the following caps may be exceeded in both the last and the last but one approved accounting periods: The number of employees must be lower than 50 (annual work force average); The turnover must be lower than 7.3 million euro (VAT excluded); 53 The balance sheet total must be lower than 3.65 million euro. II.2. CANADA Small business income Before 1982, the small business income tax rate applied to the first $150,000 of active business income of small Canadian-controlled private companies at the federal level.. This threshold was raised to $200,000 in 1982, to $225,000 in 2003, to $250,000 in 2004, to $300,000 in 2005 to $400,000 in 2007 and to $500,000 as of January 1, 2009. Most provinces provide reduced corporate income tax rates for small businesses. See note to Table II.3 for a summary of provincial corporate income tax rates on small business income. The representative sub-central government small business tax rate is an average of provincial corporate income tax rates, weighted by the provincial distribution of the federal corporate taxable income taxed at the small business rate. Manufacturing and processing income Before 2004, corporate income on manufacturing and processing (M&P) activities, not otherwise eligible for the small business rate reduction, was taxed at a lower rate at the federal level. This tax rate differential was completely phased-out between 2000 and 2004 with the general corporate income tax rate being reduced at the M&P rate level. Several provinces provide reduced corporate income tax rates on M&P income. See note to Table II.3 for a summary of provincial corporate income tax rates on M&P income. II.2. CHILE Income tax on state-owned enterprises State owned enterprises have to pay a surtax rate of 40% in addition to the basic rate of FCT. The specific tax on mining activities The specific tax on mining activities was introduced in 2006 (and modified in 2010) and is levied on income derived from the operational income of metal mining activity when obtained by a mining exploiter. Mining exploiters are defined as individuals or legal entities that extract mineral substances and sell them in any state of production. The tax is payable by those having annual sales that exceed the equivalent of the value of 12,000 metric tons of fine copper. If annual sales have an equivalent value of between 12,000 and 50,000 metric tons, the tax is paid at a progressive rate that varies between 0.5% and 4.5%.Where the annual sales are greater than the equivalent of 50,000 metric tons, and the mining operational margin obtained by the mining exploiter is equal or lower than 85, the progressive tax rate ranges from 5% to 34.5%; if the margin is greater than 85, the tax rate applicable is 14%., The value of a metric ton of fine copper is calculated according to the average value at the London Metal Exchange. Certain amounts are either added or deducted from the FCT base to calculate the operational income for mining activity. 54 Small businesses Small businesses do not have targeted income corporate taxes. However they can benefit from some special income tax regimes, where the general methodology to calculate the taxable income is modified, and some tax obligations are simplified or eliminated. II.2. CZECH REPUBLIC There are the following special activity-dependent income tax rates : pension funds shares fund investment funds 2000 25 % 25 % 25 % 2001-2003 15 % 15 % 15 % 2004 15 % 5% 5% 2005-2011 5% 5% 5% II.2. HUNGARY In the case of a so-called party carrying out activities abroad - defined in the Act 81 of 1996 on Corporate Tax and Dividend Tax - the corporate tax rate was 3 per cent in the period 2000-2003 and was 4 per cent in the period 2004-2005. This regime has been ceased since 2006. II.2. ISRAEL The Law for the Encouragement of Capital Investments was amended as of 1/1/2011. For the purposes of the law the country is divided into two areas: A Priority Area (far from the Center) and The Center of the country . To qualify for any benefits the company has to be an industrial company registered in Israel and has to prove export capability. Companies that qualify will be entitled to a lower company tax rates and, if located in the Priority Area, will also be entitled to an investment grant which will be calculated as a percentage of their approved investment as indicated below. Company Tax rates Center of the Country Priority Area Years: 2011 & 2012 15% 10% Years: 2013 & 201 12.5% 7% 2015 onwards 12% 6% Dividend Tax rate 15% 15% Investment Grant --- 20% 55 Super low company tax rate: Companies that meet the following criteria will be taxed at an even lower tax rate: 8% in the center and 5% in the Priority area. Criteria: 1. Total annual income in Israel of at least 1.5 billion LIS 2. The combined balance sheet of the company is at least 20 billion LIS. 3. The business plan of the company will include one of the following: a) Investment in productive equipment of at least 800 million LIS in the center of the country or 400 million LIS in the Priority Area over a 3 year period. b) Investment in R&D of at least 150 million NIS in the center of the country or 100 million LIS in the Priority Area c) Employing at least 500 employees in the center of the country or 250 employees in the Priority Area II.2. ITALY Targeted corporate income tax refer to the DIT and the withholding taxes on corporate reorganizations as described in the explanatory notes of table II.1. II.2. MEXICO Special Tax Treatment by Sector and Targeted Activities 2000 – 2013 Year 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Reduction in income tax for non exempt Tax reduction for book income from agricultural activities, cattle publishers, individuals and raising, forestry or fishing (corporations)1/ corporations Applicable rate (%) 50.0% 50.0% 50.0% 50.0% 50.0% 50.0% 50.0% 50.0% 50.0% 40.0% 46.7% 30.0% 44.8% 20.0% 32.1% 10.0% 32.1% N.A. 32.1% N.A. 30.0% N.A. 30.0% N.A. 30.0% N.A. 30.0% N.A. Notes: N.A. not applicable indicating that this disposition did not exist in the corresponding year, 1/In 2000 and 2001 the general reduction was 50%, and it was 25% if taxpayers industrialized their products. Source: Mexican Income Tax Law, 2000 to 2013. 56 II.2. NETHERLANDS In 2000 a reduced rate was introduced for small and medium enterprises. In 2000-2006 the reduced rate applies to the first EUR 22 689 (NLG 50 000 in 2001 and 2000) of taxable corporate income. In 2007 an additional bracket was introduced. For that year, a reduced rate of 20% was levied on the first EUR 25 000 of taxable income. Between EUR 25 000 and EUR 60 000 of taxable income, the applicable rate was 23.5%. For the tax year 2008 new tax rates and threshold were set at 20% on the first € 275.000 of taxable income. This threshold was lowered in 2009 to € 200.000. The following tables show the thresholds and statutory rates from 2006 to present: The following tables show the thresholds and statutory rates from 2006 to 2010: 2006 2007 threshold statutory rate threshold statutory rate 0 – 22689 22689 - over 25,5% 29,6% 0 – 25000 25000 – 60000 60000 – over 20% 23,5% 25,5% threshold statutory rate threshold 0 – 275000 275000 – over 20,0% 29,6% 0 – 200000 20% 200000 – over 25,5% 2008 2009 - 2010 statutory rate 2011 - present threshold statutory rate 0 – 200000 200000 – over 20,0% 25,0% II.2. NORWAY Norway has special tax regime for the shipping industry. There is a zero rate corporate tax on earnings from shipping activities (a tax on net tonnage applies). When earnings are distributed to individuals, the normal 28 per cent personal dividend tax rate applies (dividends paid to corporations are tax exempt in Norway). The resource rent from hydroelectric power production and petroleum exploitation is subject to an extra resource rent tax in addition to the normal 28 per cent corporate tax rate. The resource rent tax rate is 30 per cent for hydroelectric production and 50 per cent for petroleum production, for profits above a certain level. II.2. PORTUGAL Since the 1988 direct taxation reform, the general corporate tax rate has been gradually reduced from 36,5% to 25%. From 2009 onwards, two general tax rates are applied at a Central Government Level. A 57 general tax rate of 12,5% will be applied for the first € 12500 of taxable income and a 25% tax rate will be applied for the remaining amount of taxable income (when the total taxable income exceeds € 12500). From 2001 to 2010, small companies with annual revenues not exceeding € 149.639,37 are subject to an optional simplified tax regime based on coefficients fixed by law, with a minimum taxable income equivalent to the annual national minimum wage, and the resulting taxable income is taxed at a rate of 20% (those who so desire can opt for being subject to the general tax rules). From 1999 to 2001, a reduced corporate tax rate of 20 per cent applied to small businesses with an average gross income in 1997 and 1998 (or, in the case of businesses created after 1st January of 1999, a gross income in the first year) lower or equal to € 149.639,37. Until 2011 there was also a reduced corporate income tax rate of 15% which applies to companies located in less developed areas (10% for the first five years if it is a start-up). There are also reduced tax rates which apply to companies located in the Autonomous Region of the Azores.. From 2012 onwards there’s only one general tax rate of 25% (excluding AR Azores). II.2. SLOVAK REPUBLIC In 1994 - 2003, a special tax regime applied to taxpayers whose revenue from agricultural production was more than 50% of their total revenue. From 1994 to 1999 the tax rate was reduced to the half of the statutory tax rate. From 2000 to 2003, the tax rate was 15%. Moreover, in 1994 – 1999, if at least 60% (50% from 1997) of all employees were severely disabled (minimum 20 persons), the statutory corporate tax rate was reduced by 50%. From 2000 to 2003, the tax rate was 18%. Since 2004, no special tax rates have been applied in Slovakia. II.2. SPAIN Since 2008 as a general rule, corporate tax rate is set up at 30 per cent of the taxable income (32.5 per cent during 2007). Nevertheless, some other special corporate tax rates apply: 35 per cent in 2008 (37.5 per cent in 2007): to companies whose main activity consists of the exploration, investigation and exploitation of hydrocarbons deposits. 25 per cent: to the following incorporated companies: Mutual Insurance Companies. Mutual Guarantee Societies. Credit Cooperative Societies, Rural Savings Banks. Professional and Enterprise Associations, Trade Unions and Political Parties. Foundations and other non-profit Organisations. Cooperative Federations 58 20 per cent: to tax-privileged Cooperative Societies. 10 per cent: to certain non-profit institutions. 1 per cent: to UCITS 0 per cent: to Pension Funds Small and Medium Incorporated Business. From 2011, it is raised both the annual turnover (up to € 10 million), and the tax base threshold (up to € 300,000), to which the reduced CIT rate of 25% is applied. The remaining taxable income is taxed at 30%. Furthermore, those SME’s with a turnover below € 5 million, and an average payroll lower than 25 employees are eligible for a reduced tax rate of 20%, , and the remaining taxable income is subjet to a 25% tax rate. SME (annual turnover not exceeding € 8 million have, for tax periods starting from January 1 st 2007 onwards a reduced rate of 25%, applied up to a taxable income of € 120 202,41. Profits over the prior amount were taxed at 30% since January 1st 2007. Said that, CIT rate for small companies that maintain or increase their workforce has been temporarily decreased by 5 percentage points (20%) for the years 20092011 Until January 2005, up to a taxable income of € 120 202,41: 30 per cent. In 2002-2004 the taxable income amount threshold was € 90 151,82 and Pta 15 mill. in 2000-2001. Rest of the taxable income: 35 per cent. II.2. UNITED KINGDOM The main corporate tax rate of 23 per cent is for companies with profits over £1.5 million. Lower rates apply to lower profits: All companies with profits up to £300 000 pay at the small profits rate of 20 per cent. Those with profits between £300 001 and £1.5 million pay at 20 per cent on the first £300 000 and at 23.75 per cent on the remainder so that by £1.5 million they pay at an average rate of 23 per cent. Where a company is in a group or associated with other companies by virtue of ownership or control the thresholds are divided by the total number of connected companies. There were some differences for earlier years: For 2012-13, all companies with profits up to £300,000 paid at the small profits rate of 20 per cent on the first £300,000 and at 25 per cent on the remainder so that by £1.5 million they paid at an average rate of 24 per cent. For 2011-12, all companies with profits up to £300,000 paid at the small profits rate of 20 per cent on the first £300,000 and at 27.5 per cent on the remainder so that by £1.5 million they paid at an average rate of 26 per cent. For 2008-09, 2009-10 and 2010-11, all companies with profits up to £300 000 paid at the small companies rate of 21 per cent. Those with profits between £300 001 and £1.5 million paid at 21 per cent on the first £300 000 and at 29.75 per cent on the remainder so that by £1.5 million they paid at an average rate of 28 per cent.For 2007-08, all companies with profits up to £300 000 paid 59 at the small companies rate of 20 per cent. Those with profits between £300 001 and £1.5 million paid at 20 per cent on the first £300 000 and at 32.5 per cent on the remainder so that by £1.5 million they paid at an average rate of 30 per cent. For 2006-07, all companies with profits up to £300 000 paid at the small companies rate of 19 per cent. Those with profits between £300 001 and £1.5 million paid at 19 per cent on the first £300 000 and at 32.75 per cent on the remainder so that by £1.5 million they paid at an average rate of 30 per cent. Between 2002-03 and 2005-06 , companies with profits of £10 000 or less paid no tax (they were paying at the rate of 10 per cent in 2000-01 and 2001-02 ). Those with profits of between £10 001 and £50 000 paid nothing on the first £10 000 and at 23.75 per cent on the remainder, so that by the upper limit they are paying at an average rate of 19 per cent. In 2000-01 and 2001-02, those with profits of between £10 001 and £50 000 paid at 10 per cent on the first £10 000 and at 22.5 per cent on the remainder, so that by the upper limit they were paying at an average rate of 20 per cent. This was subject to a minimum rate of 19 per cent on all distributed profits in 2004-05 and 2005-06. Between 2002-03 and 2005-06, companies with profits between £50 001 and £300 000 paid at the small companies’ rate of 19 per cent (20 per cent in 2000-01 and 2001-02). For 2000-01 and 2001-02, all companies with profits between £300,001 and £1.5 million paid at 20 per cent on the first £300,000 and at 32.50 per cent on the remainder so that by £1.5 million they paid at an average rate of 30 per cent. Between 1981-82 and 1999-2000 the situation was simpler as there was no starting rate; there was only a small companies’ rate and a main rate. The small companies’ rate has dropped monotonically from 40 per cent in 1981-82 to 20 per cent in 1999-2000. Likewise the main rate has been lowered from 52 per cent in 1981-82 to 30 per cent in 1999-2000. The small companies’ rate applied up to £90,000 in 1981-82 but had reached a limit of £300,000 by 1999-2000. The main rate applied from £225,000 in 1981-82. By 1999-2000 the main rate applied from £1.5 million. Tax was charged between the two limits for a specific tax year in a fashion similar to that described in the first bullet above. II.2. UNITED STATES The federal income tax rate of 15 per cent applies to taxable income under $50,000; 25 per cent applies to taxable income over $50,000 and under $75,000; 34 per cent applies to taxable income over $75,000 and under $10 million; and 35 per cent applies to taxable income of $10 million or more. The benefit of lower rates is recaptured for taxable incomes between $100,000 and $18,333,333. The representative sub-central rate is a weighted average state marginal income tax rate. It was calculated by summing for all states the lowest corporate income tax rate (or the flat rate) in each state weighted by the state’s share in personal income. Beginning in 2005 taxpayers are permitted a deduction for a portion of income from US production activities, which is phased in over six years. Beginning in 2010, the deduction is nine per cent (three per cent for 2005 and 2006 and six per cent for 2007, 2008 and 2009) of the lesser of (1) qualified production activities, or (2) taxable income. The deduction is limited to 50 per cent of wages paid by the employer. 60 Part II, Table 3 II.3. CANADA The representative sub-central government tax rate is an average of provincial corporate income tax rates, weighted by the provincial distribution of the federal corporate taxable income. The provincial tax base for most Canadian provinces is identical to the federal tax base. Provinces that administer their own corporate tax systems (Quebec and Alberta) are permitted to set their own base. However, for the most part, the differences between the federal and the provincial base are not significant. Provincial corporate income tax rates as of December 31 of each year: General Statutory Corporate Income Tax Rates Newfoundland and Labrador Prince Edward Island Nova Scotia New Brunswick Quebec Ontario Manitoba Saskatchewan Alberta British Columbia Yukon Northwest Territories Nunavut 2006 14.0 16.0 16.0 13.0 9.9 14.0 14.5 14.0 10.0 12.0 15.0 11.5 12.0 2007 14.0 16.0 16.0 13.0 9.9 14.0 14.0 13.0 10.0 12.0 15.0 11.5 12.0 2008 14.0 16.0 16.0 13.0 11.4 14.0 13.0 12.0 10.0 11.0 15.0 11.5 12.0 2009 14.0 16.0 16.0 12.0 11.9 14.0 12.0 12.0 10.0 11.0 15.0 11.5 12.0 2010 14.0 16.0 16.0 11.0 11.9 12.0 12.0 12.0 10.0 10.5 15.0 11.5 12.0 2011 14.0 16.0 16.0 10.0 11.9 11.5 12.0 12.0 10.0 10.0 15.0 11.5 12.0 2012 14.0 16.0 16.0 10.0 11.9 11.5* 12.0 12.0 10.0 10.0 15.0 11.5 12.0 * The Government of Ontario proposed in its 2012 budget that legislated general corporate income tax rate cuts not be implemented and that the rate be frozen at 11.5% until the deficit is eliminated. M&P Statutory Corporate Income Tax Rates Newfoundland and Labrador Prince Edward Island Nova Scotia New Brunswick Quebec Ontario Manitoba Saskatchewan Alberta British Columbia Yukon Northwest Territories Nunavut 2006 5.0 16.0 16.0 13.0 9.9 12.0 14.5 10.0 10.0 12.0 2.5 11.5 12.0 2007 5.0 16.0 16.0 13.0 9.9 12.0 14.0 10.0 10.0 12.0 2.5 11.5 12.0 2008 5.0 16.0 16.0 13.0 11.4 12.0 13.0 10.0 10.0 11.0 2.5 11.5 12.0 2009 5.0 16.0 16.0 12.0 11.9 12.0 12.0 10.0 10.0 11.0 2.5 11.5 12.0 2010 5.0 16.0 16.0 11.0 11.9 10.0 12.0 10.0 10.0 10.5 2.5 11.5 12.0 2011 5.0 16.0 16.0 10.0 11.9 10.0 12.0 10.0 10.0 10.0 2.5 11.5 12.0 61 Small Business Statutory Corporate Income Tax Rates Newfoundland and Labrador Prince Edward Island Nova Scotia New Brunswick Quebec Ontario Manitoba Saskatchewan Alberta British Columbia Yukon Northwest Territories Nunavut 2006 5.0 5.4 5.0 1.5 8.0 5.5 4.5 5.0 3.0 4.5 4.0 4.0 4.0 2007 5.0 4.3 5.0 5.0 8.0 5.5 3.0 4.5 3.0 4.5 4.0 4.0 4.0 2008 5.0 3.2 5.0 5.0 8.0 5.5 2.0 4.5 3.0 2.5 4.0 4.0 4.0 2009 5.0 2.1 5.0 5.0 8.0 5.5 1.0 4.5 3.0 2.5 4.0 4.0 4.0 2010 4.0 1.0 5.0 5.0 8.0 4.5 0.0 4.5 3.0 2.5 4.0 4.0 4.0 2011 4.0 1.0 4.5 5.0 8.0 4.5 0.0 2.0 3.0 2.5 4.0 4.0 4.0 II.3. GERMANY The representative sub-central government corporate income tax rate is for Berlin. In the years between 2000 and 2007 the rate was 0.05 (general rate) * 410 per cent (local “Hebesatz”) = 20.5 per cent. As the local business tax was deductible from its own base, the effective rate was 20.5 / 120.5 = 17 per cent. With the Corporate Tax Reform in 2008 the representative sub-central government corporate income tax rate was changed to 14.35 per cent (0.035 general rate * 410 per cent “Hebesatz”). The local business tax is no longer deductible from its own base. II.3. LUXEMBOURG The representative sub-central government corporate income tax rate is for Luxembourg City. The rate is 0.03 (general rate) * 225 per cent (taux communal) = 6.75 per cent. II.3. KOREA A uniform sub-central government tax rate of 10 per cent is used as a representative rate. The local government can adjust the rate between a lower limit of 5 per cent and an upper limit of 15 per cent. However, in practice all use the 10 per cent rate. II.3. NORWAY From 2005 revenue-sharing between the central and local government of income tax from corporations was reintroduced (a similar system was abolished in 1999). Under this revenue-sharing arrangement, revenue equal to 4.25 percentage points of the overall corporate tax rate of 28 per cent are allocated to a sub-central government tax fund and distributed to local governments based on certain criteria (mainly based on the local share of employment). The rest (23.75 percentage points) is allocated to the central government. As from 2007, the corporate revenue-sharing between the central and local government was again abolished. II.3. PORTUGAL As from 2007, local authorities may levy a non deductible surcharge of up to 1.5 % of the taxable 62 profit before the deduction of tax losses and tax benefits. In previous years, the corporate income tax liability could be increased by a local surcharge, up to a limit of 10 per cent of the central government tax gross of tax credits. II.3. SWITZERLAND The representative sub-central adjusted rate: City of Zurich in the canton of Zurich corresponds to the calculation made in Table I.5. A church tax at the cantonal level is also applicable. Corporate taxes paid are deductible from their own bases and from the central, sub-central and local tax bases. Minimum sub-central adjusted rate: Canton of Lucerne. Maximum sub-central rate: Canton of Geneva. Cf also explanatory note to Table II.1 for Switzerland. For companies the church taxes are included, as business cannot avoid them. Information on the rates excluding the church tax is provided as comments in the table itself. II.3. UNITED STATES The representative sub-central rate is a weighted average state corporate income tax rate. See the explanatory notes to table II.1. Seven states (and many localities) do not impose corporate income tax. The maximum sub-central rate applies to Philadelphia, Pennsylvania. General note to Part II, Table 4 This table reports on the tax treatment of domestic dividend income by showing the effective tax rates on distribution of domestic source of income to a resident individual shareholder. The pre-tax distributed profit (gross profits), shown in column 3, is income before corporate tax that a corporate firm must earn to pay out 100 in dividend. For example, a pre-tax distributed profit of 125 with a corporate tax rate of 20 per cent suffices to distribute a dividend of 100. The pre-tax distributed profits is equal to 100 / (1-X), where X is the corporate income tax rate on distributed profits. The distributed profits (dividend), shown in column 4, is the amount of profits, net of corporate taxes, distributed by the corporate firm to its shareholders. The grossed-up dividend (column 7) is the taxable amount of dividend for personal income tax purposes. For example when a company pays out a dividend of 100 and the shareholder is required to gross-up his dividend with a tax credit of 40, the base for the personal income tax becomes 140. Given a 40 per cent marginal tax rate the personal income tax becomes 56 (0.4*140), from which the imputation tax credit of 40 can be deducted, yielding a final individual income tax of 16. Dividends can conform to one of a number of possible tax treatments: A classical system treats corporations and investors as separated entities, taxing profits first at the corporate level, and then taxing after-corporate tax profits again at the shareholder level when that income is distributed to them as a dividend. A modified classical system implies that dividend income is taxed at lower rates than other forms for capital income at the shareholder level. An imputation system is a system under which part or all of the corporate income tax paid by a company on its profits is credited against the personal income tax liability of the shareholders in receipt of 63 dividends. The imputation reduces or eliminates the double taxation of distributed profits which arises under the classical system of taxation. Many countries have adopted an imputation system in one form or another. The system may be a "full imputation system" where the shareholder is entitled to full credit for corporate income tax paid, or it may be a "partial imputation credit" where the shareholder is only granted a partial credit for corporate income tax paid. A partial inclusion system implies that only a fraction of the dividend income is included as taxable income at the personal level. Several OECD countries have recently introduced such a system, in some countries replacing an imputation system and in others replacing some sort of a classical system. Partial inclusion is in practice similar to a modified classical system, but where there is a reduction in taxable income instead of a reduction in the tax rate for dividend income. An exemption system (no shareholder taxation) implies that if gross profits of 166.67 are subject to a 40 per cent corporate tax rate, a net dividend of 100 is distributed to the shareholder, which is exempt from personal income tax. A split-rate system is a system of corporate income tax under which different rates of corporate income tax are levied on retained and distributed profits (without applying the imputation system). A preferential treatment is generally granted to distributed profits in the form of a lower rate of tax, the rational being that distributed profits will be subject to additional tax in the hands of the shareholders. The purpose of a split-rate system is to reduce the double taxation of dividends. Germany is the only OECD country that has had this system, but it was abolished in 2001. Part II, Table 4 II.4. AUSTRIA Dividends received by a resident individual from a resident company are subject to a final withholding tax at a rate of 25 per cent. II.4. BELGIUM Up till 2011 the withholding tax was final if the shareholder so chose (and most shareholders did).The standard withholding and personal income tax rate was 25% although a reduced rate of 15% applied to Belgian shares issued after 1 January 1994. In 2012, the tax treatment of dividend income differed according to several factors: the withholding tax paid at source. At source, the withholding tax rate was 25% for “old” shares and 21% for Belgian shares issued after 1/1/1994. In the latter case however, the investor could opt to pay an extra 4% at source. In the PIT return the taxpayer had to declare (upon honour) whether the annual threshold (EUR 20020) for qualifying interest and dividend income was exceeded or not. Not all dividend and interest income was taken into consideration, among the disregarded items were interest from ordinary saving accounts, as well as dividend and interest income for which the extra 4% had been paid at source. When 25% or 21%+4% was paid at source, the withholding tax was final if the shareholder so chose. When only 21% was paid at source, inclusion in PIT return was mandatory or optional depending whether the annual threshold was exceeded or not. When the income was included in the PIT-return, the tax 64 administration selected the most beneficial treatment for the taxpayer: distinct taxation at the same rate as the withholding tax rate (21%, 21%+4% or 25%) or aggregation with other sources of income. In 2013 this complex system was abolished and replaced by a single withholding tax rate of 25% for all dividends. This withholding tax is final if the shareholder so chooses. The lower the return on equity before tax, the lower the effective CIT rate due to the allowance for corporate equity (ACE). E.g. the effective tax rate is only half the nominal tax rate when the return on equity before tax (gROE) is twice the notional interest rate (2.742% in 2013, 3.242% for small and medium enterprises). non-SMEs 2013 without ACE gROE / ACE-rate 2 ACE-rate 2013 Gross return on equity (gROE) Type of dividend treatment 0 5.484 CL gROE = 2 ACE-rate 2 2.742 gROE = 3 ACE-rate 3 2.742 gROE = 4 ACE-rate 4 2.742 5.484 8.226 10.968 CL CL CL CIT rate on distributed profits 34.0 17.0 22.7 25.5 Pre-tax distributed profits 151.5 120.5 129.3 134.2 100 100 100 100 25 25 25 25 25 25 25 25 Overall PIT + CIT rate 50,5 37,7 42,0 44,1 CIT/PIT+CIT 67,3 45,0 54,0 57,8 PIT/PIT+CIT 32,7 55,0 46,0 42,2 Distributed profits Final withholding tax PIT rate on (grossed-up) dividend Grossed up dividend Imputation rate Imputation / dividend tax credit Net personal tax II.4. CANADA In column 6, the applied sub-central rate corresponds to the representative sub-central government tax rate as reported on table I.7. The dividend credit rate reported reflects the federal dividend tax credit of 15.0198 per cent and the provincial dividend tax credit. Effective provincial dividend tax credits vary by province. For the representative city case, Ontario’s effective dividend tax credit rate is 9.98 per cent (6.4 per cent plus impact of surtax). II.4. CHILE Intercompany dividends and profits distributed between domiciled companies are not liable to the First Category tax because the tax has already been paid on those profits by the company making the distribution. II.4. FINLAND 70% of dividends from listed companies are included in taxable capital income. 65 For non-listed companies part of the dividends may be taxed as earned income. Dividends from nonlisted companies are not taxed at the hands of the shareholders if the dividend does not exceed the 9 % annual return on the net wealth. If this 9% yield is higher than the maximum amount of € 60,000, 70% of the exceeding amount is taxed as capital income and 30 % is tax-exempt income. Capital income tax rate is 30 % up to EUR 50 000, and the exceeding amount is taxed at the rate of 32 %. Of the distributed dividends in excess of the annual return of 9%, 70% is regarded as taxable earned income and 30% as taxexempt income for shareholders. II.4 FRANCE The rates in Table II.4 and the following explanations are related to the situation in force in January 1st of the year of the income (the personal income taxation is usually one year later). The dividends are subject to: CIT at a rate of 34.43 % (cf. II-1); Additional contribution on distributed profit (3 %); Social contributions (particularly CSG and CRDS) of 15.5%; Exceptional contribution on high incomes (top rate of 4% when total income is over 500 000 for single persons and 1 000 000 € for couples). Personal income tax: top PIT rate of 45% with a 40 % allowance on dividends to temper the double taxation (CIT and PIT). The tax base is further reduced by a part of the social contributions already paid (5.1 % of the gross dividends). Between 2008 and 2012, the taxpayer could choose between the progressive income tax schedule and a final withholding tax (created in 2008). It was rational for a high income tax payer to choose the final withholding tax. From January 1st 2013, distributed dividends become liable to progressive income tax schedule. Besides, a mandatory creditable withholding tax of 21% is applied on these revenues. The other main changes in the taxation of the dividends between 2008 and 2013 were : top PIT rate was 40% in 2008 and 2009, 41% from 2010 and 45% from 2012 ; the final withholding tax rate was 18% from 2008 to 2010, 19 % in 2011 ; and 21 % in 2012. from 2011, an exceptional contribution on high incomes is applied. It is based on the reference taxable income (“revenu fiscal de référence”). The top rate is 4% over 500 000 € for single persons and 1 000 000 € for couples. social contributions rate was set at 11% in 2008, 12.10% in 2009, 12.3 % in January 2011, 13.5 % in October 2011 and 15.5% from July 2012. II.4. GERMANY The 2008 Corporate Tax Reform has fundamentally changed the taxation of corporate income. The central government corporate income tax rate has been lowered from 25 to 15 per cent. The reform also 66 reduced the sub-central government corporate income tax, which is now no longer deductible. This part of the Reform came into force in the year 2008 and applies to corporate profits of this year onwards. The corporate profits of the year 2007 that were distributed as dividends in 2008 were subject to the old legislation, i.e. half of dividend income was included into tax assessment and taxed with a maximum income tax rate of 45 per cent. The second part of the Corporate Tax Reform that came into force in 2009 changed the taxation of dividends. It refers to dividends distributed from corporate profits of the year 2008 already subject to the new legislation. The withholding tax is now final at a rate of 25 per cent with an option for including dividend income into income tax assessment. Together with a surtax of 5.5 per cent, the net personel tax rate amounts to 26.4 per cent. II.4. GREECE 1. Corporations (SAs) Over the last decade, Greece has been reducing the statutory corporate tax rate, which was 40% in 2000. The tax reform of 2008 foresaw a gradual reduction by 1% per year of the rate for the years between 2010 and 2014 (from 25% to 20%). In 2012, the statutory Corporate Income Tax was 20%, whereas a 25% withholding tax applied to distributed profits in the form of dividends, Board and Directors fees, additional compensation of directors and employees other than wages, as well as interim dividend payments. Under the Law 4110/2013, the statutory Corporate Income Tax for 2013 onwards is 26% and the withholding tax rate on profit distributions approved as of 1.1.2014 is 10%.. 2. Limited Liability Companies (LLCs) & Private Capital Companies (PCCs) In general, Limited Liability Companies and Private Capital Companies are treated the same way with Corporations. 3. Partnerships, civil law communities, joint ventures, and other entities. From 2007 onward to 2012, the tax rate imposed on the profits corresponding to the shares of individual unlimited partners of OE and EE, was 20%. and for all the other cases (profits of legal entities partners, limited partners of EE, joint ventures, civil, participation, nominee, legal services companies), the applicable tax rate was 25%. From 2013 onwards, all legal entities are taxed at a rate of 26% for income up to 50.000€ and 33% for any exceeding amount. However, the entities which maintain double entry accounting books, have the same tax treatment with Corporations (26% tax rate & 10% withholding tax rate on distributed profits). For more details see explanatory notes to Table II.1. 67 General note to Part II, Table 4 TAX RATES FOR LEGAL ENTITIES (1993 – 2012) Type of legal person Limited & unlimited partnerships, Civil law communities Joint ventures, Civil companies, Participation and nominee companies Legal services companies of L.518/89, Notary companies of L.284/93 1/1/1993– 31/12/1998 1/1/199931/12/1999 1/1/2000 – 31/12/2004 1/1/200531/12/2005 1/1/200631/12/2006 1/1/200731/12/09 1/1/1031/12/12 35% 30% 25% 24% 22% 20% 20% 35% 35% 35% 32% 29% 25% 25% 35% 30% 25% 25% 25% 25% 25% Partnerships, joint ventures - other legal entities maintaining single entry accounting books (2013 onwards) Income bracket (€) 50.000 Excess Tax rate (%) 26% Tax bracket (€) 13.000 Total amount of Income (€) 50.000 Tax (€) 13.000 33% II.4. HUNGARY PIT on the dividends paid as from 2011 is generally 16 per cent with additional 14% health contribution which is capped at 450,000 HUF.. Tax on the dividends paid in the period 2009-2010 was 25 per cent, with additional 14% health contribution, which is capped at 450,000 HUF. From 2007 until 2011 dividends paid by companies registered at the stock exchange were taxed by a rate of 10 per cent. PIT on the dividends paid in the period 2004-2008 was determined as follows: 1. the value falling on the private person in question from the part of the equity of the business association was calculated in proportion to the pecuniary stake (share, business quota, property note etc.) of the private person entitled to dividend; 68 2. the part of the amount indicated in paragraph a) was multiplied by 0.3; and 3. the rate of tax was 20 per cent (in the case of dividends paid in the period 2004-) and was 25 per cent (in the case of dividends paid in the period 2005-2008) on the part of the amount paid to the private person on grounds of dividend and not exceeding the amount determined in paragraph b), while the rate of the tax on the further part was 35 per cent. 4. In 2007-2008 with additional 14% health contribution which is capped at 450,000 HUF. In 2006 with additional 4% health contribution which is capped at 400,000 HUF. Tax on the dividends paid in the period 2000-2003 was determined as follows: the value falling on the private person in question from the part of the equity of the business association was calculated in proportion to the pecuniary stake (share, business quota, property note etc.) of the private person entitled to dividend; the part of the amount indicated in paragraph a) was calculated in accordance with double the basic rate of interest of the central bank valid on the first day of the year of establishment of the dividend; and the rate of tax was 20 per cent on the part of the amount paid to the private person on grounds of dividend and not exceeding the amount determined in paragraph b), while the rate of the tax on the further part was 46 per cent (= personal income tax of 35 + in 2000-2002 with additional 11% health contribution). II.4. IRELAND From 1999 Ireland moved from a partial imputation system to a classical system. Dividend tax credits are shown in the following table: Period Tax credit 3/12/1997 to 5/4/1999 11/89 6/4/1997 to 2/12/1997 21/79 6/4/1995 to 5/4/1997 23/77 6/4/1991 to 5/4/1995 25/75 6/4/1989 to 5/4/1991 28/72 6/4/1988 to 5/4/1989 32/68 6/4/1983 to 5/4/1988 35/65 6/4/1978 to 5/4/1983 30/70 The Irish tax year changed in 2001 from April-April to calendar year. Tax credits in Table II.4 have been weighted to express them in terms of calendar year in the calculations for years 1983, 1988, 1989, 1991, 1995 and 1997 as in the following example for the year 1983: tax credit = ((30/70)*3(35/65)*9)/12. II.4. ISRAEL From 1987 and until 2005 Israeli individuals paid a 25 percent tax on dividends received from Israeli companies. In 2006 the rate was lowered to 20 percent for regular shareholders but maintained at 25 69 percent for ‘substantial shareholders’( ie those with an interest in the company of greater than 10 percent ). In 2012 the rate was increased to 25% for regular shareholders and to 30% for ‘substantial shareholders' Also from 2006, a Holding company is exempt from Israeli tax on dividends received and capital gains from the sale of Held Companies in which it has a 10 percent shareholding interest and interest, dividends and capital gains from securities publicly traded in the Israeli Stock Exchange. Dividends paid from the Holding Company to foreign shareholders are subject to a 5 percent tax and a foreign shareholder will enjoy a capital gain exemption upon its sale of shares in the Holding Company. II.4. ITALY Up to 1998 the following rules applied: the company pays IRPEG in year t and distributes the dividends in year t+1. The shareholder pays IRFEF in year t+1 when he receives his dividend and receives an imputation tax credit for the IRPEG paid in year t (these rules applied under the imputation system in force until 2003). The data in table II.4 relates to the taxes in year t and does not consider that the tax credit is received only in year t+1. For the years from 1981 to 1997, in which ILOR was in force, the rate shown in column 2 for CIT on distributed dividends is the result of the sum of the IRPEG and ILOR rates, adjusted, if necessary, to make allowance for the deductibility of ILOR from the IRPEG taxable base. The tax credit was nevertheless only allowed for the IRPEG paid on the dividend (column 8 only shows the IRPEG rate). From 1998, taxpayers with “non-qualified” shareholdings could opt for a final withholding tax with a rate of 12.5% instead of having their dividends taxed under the ordinary personal income tax (IRPEF). The fixed withholding tax is always advantageous for taxpayers with “non-qualified” shareholdings paying the top marginal PIT rate. Also in case of capital gains from “non-qualified” shareholdings and interest income the taxpayer can opt for a final withholding tax at the rate of 12.5%. After 1st January 2012 (Law Decree 201/2011), the tax rate applied to dividend income from nonqualified shareholdings and to capital gains realized on non-qualified shareholdings is equal to 20%. From 1998 onwards, the tables report the dividends tax treatment for individual taxpayers with “nonqualified” shareholdings.2 The taxation of dividends for individual taxpayers with “qualified” shareholdings has changed as of 1 January 2004, when a new corporate income tax, IRES, was introduced with a statutory tax rate of 33%. The imputation method previously used to eliminate dividend double taxation has been replaced with the exemption method: dividends are exempted up to 60% for taxpayers subject to IRPEF. 2 “Qualified” shareholdings refer to a percentage of voting rights greater than 2% or 20% depending on whether the company is respectively listed at the stock exchange or not; equivalently, a shareholding is “qualified” if it represents a holding in the capital greater than 5% or 25% depending on whether the company is respectively listed at the stock exchange or not. 70 Because the corporate income tax rate was reduced from 33% to 27.5% with effect from 1 January 2008, new percentages of exemption/taxation for dividends and capital gains from qualifying participations are implemented to match such reduction, while maintaining the level of the overall tax burden. Specifically, the new percentage of taxation is 49.72%, and the new percentage of exemption is correspondingly reduced from 60% to 50.28%. The new exemption/taxation percentage applies to: dividends paid out of profits realized on the tax period starting on or after 31 December 2007 capital gains realized after 1 January 2009 II.4. KOREA There is a withholding tax rate on interests and dividends of 14 per cent (15 per cent prior to 2005). Income from interest and dividend exceeding 20 million is subject to global taxation (taxed as ordinary income under the personal income tax). II.4. MEXICO In 2013 , distributed dividend income is subject to the regular corporate income tax of 30 per cent calculated on the basis of the grossed-up dividend. Individuals must consider the grossed-up dividend as part of their taxable income and may credit against their personal income tax liability the 30 per cent tax already paid by the firm. A similar system has been applied since 2002. In 2001 and 2000, the distributed dividend income was subject to the regular corporate income tax rate of 35 per cent, plus a 5 per cent withholding tax calculated on the basis of the grossed-up dividend. For individuals, the 40 per cent tax was either final or creditable against personal income tax liabilities. Reinvested profits paid the deferred 5 per cent corporate income tax when they were distributed as dividends. II.4. NETHERLANDS A rate of 25% applies to all income from substantial interests in the hands of the shareholder. A taxpayer is regarded as having a substantial interest in a company if she/he, either alone or together with his partner, holds, directly or indirectly, at least 5% of the shares of that company. The table does not model the tax burden on distributed dividends when the shareholder does not have a substantial holding in the company. When shares do not qualify as a substantial interest, a return of 4% is deemed to be received on the value of the underlying ‘ordinary’ shares and (since 2001) this deemed return is taxed at a rate of 30%. This ‘presumptive capital income tax’ has been introduced as from January 2001 and applies (except in case of a substantial holding) to all personal income from savings and investments (e.g. interest, dividend, capital gain). For 2007, the PIT rate applicable to taxable income from substantial interests was reduced for one year to 22% for the first EUR 250 000. From 2008 the rate of 25% returned into force. Foreign taxpayers are subject to a final withholding tax on dividends of 15% (dividend tax). II.4. NORWAY Norway abolished the full imputation system in 2006 and introduced personal taxation of dividends and gains (the Shareholder Model). The total effective tax rate (CIT + PIT) on dividends is 48,16 pct., and the shareholder is allowed a deduction equal to the risk-free market interest rate times the cost price of the share. 71 II.4. PORTUGAL As from 2013, the dividend income is subject to a 28% final withholding tax. However, the taxpayer may opt to include 50 per cent of the dividend income in his taxable income and be taxed at the general personal income tax rates. From 2002 to 2005, 50 per cent of the dividend income is added to the taxable income and subject to the general personal income tax rates. In 2000 and 2001, the dividend income could be included in the taxable income by option of the taxpayer in which case he was entitled to a tax credit in the amount of the withholding tax as well as to another tax credit corresponding to an amount equal to 60 per cent of the corporate income tax levied on the profits placed at the disposal of the beneficiaries. II.4. SLOVENIA In the years 2000 - 2005 a partial inclusion system was in place with a proportion of dividend income being taxed progressively with the top marginal personal income tax rate of 50 per cent. In 2006 this was replaced by the classical system within the dual income approach. Under the new system, income from capital (ie interest, dividends and capital gains) has been taxed at proportionate rates on a scheduler basis. Dividends are taxed at a proportionate rate of 25% since 2013 (20 % till 2012). II.4. SWITZERLAND Combined (central and sub-central and local) top marginal personal income tax rate after applying the multiple for sub-central and local taxes where applicable,, as reported in Tables I.5-I.7, imposed on dividend income in the city of Zurich, canton of Zurich. Zurich employs a MCL system (dividend income is taxed at 50% of the income tax rate at the shareholder level for participations exceeding 10%) as of 1.1.2008. The church tax is excluded, as individuals can avoid paying church taxes. For federal tax, a MCL system is employed as of 1.1. 2009 (dividend income is taxed at 50% of the income tax rate at the shareholder level for participations exceeding 10%). II.4. UNITED STATES The combined (central and sub-central) top marginal personal income tax rate includes a weighted average state marginal income tax rate on dividend income provided by the National Bureau of Economic Research (www. nber.org). PART III. SOCIAL SECURITY CONTRIBUTION TABLES Part III, Table 1 III.1. AUSTRIA The SSC rates are for workers, and they are lower for other employees. They also include 72 Contributions for the promotion of residential buildings (Payroll tax in Revenue Statistics) and for the Chamber of Labour (Tax on Income in RevSt), which are levied by health security institutions on the same base (but only on 12 current pays) as SSC. The lower threshold is not a contribution-free amount which is deducted from the base, but an amount below which the employee can choose to be insured by social security, in which case pension and health SSC (no unemployment insurance) amounts to 54,9 € in 2013 (2012: 53.10€ all amounts for a worker) per month would have to be paid. For employees above the threshold, the whole gross income (up to the upper threshold) is taken as base for SSC. III.1. BELGIUM The rate of the personal social security contribution listed in table III.1 is the sum of different items. Up to the third quarter of 1982 there were upper thresholds for some items. These thresholds were abolished starting form October 1982. total Employee ssc 1980Q1 1980Q2 1980Q3 1980Q4 1981Q1 1981Q2 1981Q3 1981Q4 1982Q1 1982Q2 1982Q3 1982Q4 in % 10,1 10,1 10,1 10,13 10,1 10,4 10,4 10,4 10,07 10,82 10,82 10,82 of wich upper treshold (BEF per quarter) pension s Medical care sickness allowance s 6 6 6 6 6,25 6,25 6,25 6,25 6,25 7 7 7 1,8 1,8 1,8 1,8 1,8 1,8 1,8 1,8 1,8 1,8 1,8 1,8 1,1 1,1 1,1 1,13 1,15 1,15 1,15 1,15 1,15 1,15 1,15 1,15 Unemployment 1,2 1,2 1,2 1,2 0,9 1,2 1,2 1,2 0,87 0,87 0,87 0,87 pensions 54150 55225 56325 70400 71800 73225 73225 76200 95625 97525 99475 - Medical care - Sickness allowances 54150 55225 56325 70400 71800 73225 73225 76200 95625 97525 99475 - Unemployment 32750 33400 34075 34750 71800 - Since 1.1.2000, a reduction in personal social security contributions is granted for low salaries. This “workbonus” is granted monthly in accordance with the level of the salary. Table of the reduction in personal social security contributions for an employee, in €, from 1.01.2013) Yearly gross salary (Sb) in € 0 < Sb < 18 021.84 18 021.84 < Sb < 28 624.92 Sb > 28 624.92 Yearly reduction in € 2 100 2 100 - 0.1981 (Sb – 18 021.84) 0 Yearly maximum in € 2 100.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.12.2012) Yearly gross salary (Sb) in € 0 < Sb < 18 021.84 18 021.84 < Sb < 21 996.60 21 996.60 < Sb < 28 624.92 Sb > 28 624.92 Yearly reduction in € 2 100 2 100 - 0.2584 (Sb – 18 021.84) 1 716 - 0.1618 (Sb – 18 021.84) 0 Yearly maximum in € 2 100.00 73 Table of the reduction in personal social security contributions for an employee, in €, from 1.02.2012) Yearly gross salary (Sb) in € 0 < Sb < 17 668.80 17 668.80 < Sb < 21 565.56 21 565.56 < Sb < 28 062.96 Sb > 28 062.96 Yearly reduction in € 2 100 2 100 - 0.2636 (Sb – 17 668.80) 1 716 - 0.1651 (Sb – 17 668.80) 0 Yearly maximum in € 2 100.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.05.2011) Yearly gross salary (Sb) in € 0 < Sb < 17 322.48 17 322.48 < Sb < 21 142.80 21 142.80 < Sb < 27 511.92 Sb > 27 511.92 Yearly reduction in € 2 100 2 100 - 0.2743 (Sb – 17 322.48) 1 716 - 0.1718 (Sb – 17 322.48) 0 Yearly maximum in € 2 100.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.09.2010) Yearly gross salary (Sb) in € 0 < Sb < 16 982.88 16 982.88 < Sb < 20 728.44 20 728.44 < Sb < 26 973.96 Sb > 26 973.96 Yearly reduction in € 2 100 2 100 - 0.2743 (Sb – 16 982.88) 1 716 - 0.1718 (Sb – 16 982.88) 0 Yearly maximum in € 2 100.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.10.2008) Yearly gross salary (Sb) in € 0 < Sb < 16 649.88 16 649.88 < Sb < 20 322.00 20 322.00 < Sb < 26 444.64 Sb > 26 444.64 Yearly reduction in € 2 100 2 100 - 0.2798 (Sb – 16 649.88) 1 716 - 0.1752 (Sb – 16 649.88) 0 Yearly maximum in € 2 100.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.9.2008) Yearly gross salary (Sb) in € 0 < Sb < 16 349.88 16 349.88 < Sb < 26 444.64 Sb > 26 444.64 Yearly reduction in € 1 716 1 716 - 0.1700 (Sb – 16 349.88) 0 Yearly maximum in € 1 812.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.5.2008) Yearly gross salary (Sb) in € 0 < Sb < 16 029.36 16 029.36 < Sb < 25 926.12 Sb > 25 926.12 Yearly reduction in € 1 716 1 716 – 0.1734 (Sb – 16 029.36) 0 Yearly maximum in € 1 716.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.1.2008) Yearly gross salary (Sb) in € 0 < Sb < 15 715.08 15 715.08 < Sb < 25 418.52 Yearly reduction in € 1 716 1 716 - 0.1768 (Sb – 15 715.08) Yearly maximum in € 1 716.00 74 Sb > 25 418.52 0 Table of the reduction in personal social security contributions for an employee, in €, from 1.4.2007) Yearly gross salary (Sb) in € 0 < Sb < 15 406.92 Yearly reduction in € 1 716 Yearly maximum in € 15 406.92 < Sb < 24 919.56 Sb > 24 919.56 1 716 - 0.1804 (Sb – 15 406.92) 0 1 707.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.10.2006) Yearly gross salary (Sb) in € 0 < Sb < 15 106.56 15 106.56 < Sb < 24 919.56 Sb > 24 919.56 Yearly reduction in € 1 680 1 680 - 0.1712 (Sb – 15 106.56) 0 Yearly maximum in € 1 680.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.1.2006) Yearly gross salary (Sb) in € 0 < Sb < 14 810.76 14 810.76 < Sb < 24 431.52 Sb > 24 431.52 Yearly reduction in € 1 680 1 680 - 0.1746 (Sb – 14 810.76) 0 Yearly maximum in € 1 680.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.8.2005) Yearly gross salary (Sb) in € 0 < Sb < 14 810.76 14 810.76 < Sb < 20 441.04 Sb > 20 441.04 Yearly reduction in € 1 500 1 500 - 0.2664 (Sb – 14 810.76) 0 Yearly maximum in € 1 440.00 Table of the reduction in personal social security contributions for an employee, in €, from 1.4.2005) Yearly gross salary (Sb) in € 0 < Sb < 14 520.12 14 520.12 < Sb < 20 040.00 Sb > 20 040.00 Yearly reduction in € 1 500 1 500 - 0.2717 (Sb – 14 520.12) 0 Yearly maximum in € 1 440.00 Table of the reduction in personal social security contributions for an employee, in €, on 1.1.2005) Yearly gross salary (Sb) in € 0 < Sb < 14 328.36 14 328.36 < Sb < 20 040.00 Sb > 20 040.00 Yearly reduction in € 1 260 1 260 - 0.2206 (Sb – 14 328.36) 0 Yearly maximum in € 1 440.00 Table of the reduction in personal social security contributions for an employee, in €, on 1.10.2004) Yearly gross salary (Sb) in € 0 < Sb < 14 615.64 14 615.64 < Sb < 18 841.92 Sb > 18 841.92 Yearly reduction in € 1 140 1 140 - 0.2697 (Sb – 14 615.64) 0 Yearly maximum in € 1 140.00 75 Table of the reduction in personal social security contributions for an employee, in €, on 1.1.2004) Yearly gross salary (Sb) in € 0 < Sb < 14 328.36 14 328.36 < Sb < 18 471.60 Sb > 18 471.60 Yearly reduction in € 1 140 1 140 - 0.2751 (Sb – 14 328.36) 0 Yearly maximum in € 1 140.00 Table of the reduction in personal social security contributions for an employee, in €, on 1.6.2003) Yearly gross salary (Sb) in € 0 < Sb < 10 947.48 10 947.48 < Sb < 14 328.36 14 328.36 < Sb < 18 471.60 Sb > 18 471.60 Yearly reduction in € 0 1 140 1 140 - 0.2751 (Sb – 14 328.36) 0 Yearly maximum in € 1 140.00 Table of the reduction in personal social security contributions for an employee, in €, on 1.1.2003) Yearly gross salary (Sb) in € 0 < Sb < 10 733.04 10 733.04 < Sb < 14 047.68 14 047.68 < Sb < 18 110.04 Sb > 18 110.04 Yearly reduction in € 0 1 140 1 140 - 0.2806 (Sb – 14 047.68) 0 Yearly maximum in € 1 140.00 Table of the reduction in personal social security contributions for an employee, in €, on 1.2.2002) Yearly gross salary (Sb) in € 0 < Sb < 10 733.04 10 733.04 < Sb < 14 047.68 14 047.68 < Sb < 16 731.00 Sb > 16 731.00 Yearly reduction in € 0 981.60 981.60 - 0.3658 (Sb – 14 047.68) 0 Yearly maximum in € 981.66 Table of the reduction in personal social security contributions for an employee, in €, on 1.6.2001) Yearly gross salary (Sb) in € Yearly reduction in € 0 < Sb < 10 522.80 0 10 582.80 < Sb < 13 772.40 981.60 13 772.40 < Sb < 16 402.92 981.60 - 0.3732 (Sb – 13 772.40) Sb > 16 402.92 0 Table of the reduction in personal social security contributions, in €, on 1.9.2000) Yearly gross salary (Sba) in € 0 < Sba < 10 316.28 10 316.28 < Sba < 13 502.28 13 502.28 <Sba < 16 081.32 Sba > 16 081.32 Reduction in € 0 981.60 981.60 - 0.3806 (Sba - 13 502.28) 0 Yearly maximum in € 981.66 Yearly maximum in € 929.60 Table of the reduction in personal social security contributions, in €, on 1.7.2000) Yearly gross salary (Sba) in € 0 < Sba < 10 106.88 Reduction in € 0 Yearly maximum in € 929.60 76 10 106.88 < Sba < 13 237.56 13 237.56 <Sba < 15 766.08 Sba > 15 766.08 981.60 981.60 - 0.3882 (Sba - 13 237.56) 0 Table of the reduction in personal social security contributions, in €, on 1.4.2000) Yearly gross salary (Sba) in € 0 < Sba < 10 106.88 10 106.88 < Sba < 13 237.56 13 237.56 <Sba < 15 766.08 Sba > 15 766.08 Reduction in € 0 981.60 981.60 - 0.39 (Sba - 13 237.56) 0 Yearly maximum in € 929.60 Table of the reduction in personal social security contributions, in €, on 1.1.2000) Yearly gross salary (Sba) 0 < Sba < 10 106.88 10 106.88 < Sba < 12 642.60 12 642.60 <Sba < 14 576.16 Sba > 14 576.16 Reduction 0 773.40 773.40 - 0.4 (Sba – 12 642.60) 0 Yearly maximum in € 929.60 III.1. CANADA Employment Insurance (EI) provides temporary financial help to unemployed Canadians while they look for work or upgrade their skills, while they are pregnant or caring for a new-born or adopted child, or while they are sick. Active re-employment benefits and support measures are delivered in co-operation with the provinces and territories. For 2013, employee Employment Insurance contributions are 1.88 per cent of annual earnings up to $47 400. Those contributions were 2.4 per cent, 2.25 per cent, 2.22 per cent, 2.1 per cent, 1.98 per cent, 1.95 per cent, 1.87 per cent, 1.80 per cent, 1.73 per cent, 1.73 per cent, 1.73 per cent,1.78 per cent and 1.83 per cent in 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011 and 2012 respectively. The Canada Pension Plan (CPP) is a compulsory earnings-based national plan that provides retirement pensions – as well as survivor, disability and death benefits. The Plan is financed by contributions and investment returns on accumulated assets. Benefit levels are linked to earnings on which contributions are made. CPP revenues, assets and expenditures are not included in the accounts of the government of Canada. The province of Quebec administers and operates a parallel program, the Quebec Pension Plan (QPP). Starting in 2012, employee Quebec Pension Plan contributions are no longer harmonized with employee Canada Pension Plan contributions. For the year 2013, employee Canada Pension Plan and Quebec Pension Plan contributions are respectively 4.95 per cent and 5.1 per cent of annual earnings between $3 500 and $51 100. Those contributions were 3.9 per cent of annual earnings between $3 500 and $37 600 in 2000, 4.3 per cent of annual earnings between $3 500 and $38 300 in 2001, 4.7 per cent of annual earnings between $3 500 and $39 100 in 2002, 4.95 per cent of annual earnings between $3 500 and $39 900 in 2003, 4.95 per cent of annual earnings between $3 500 and $40 500 in 2004, 4.95 per cent of annual earnings between $3 500 and $41 100 in 2005, 4.95 per cent of annual earnings between $3 500 and $42 100 in 2006 and 4.95 per cent of annual earnings between $3 500 and $43 700 in 2007,4.95 per cent of annual earnings between $3 500 and $44 900 in 2008, 4.95 per cent of annual earnings between $3 500 and $46 300 in 2009, 4.95 per cent of annual earnings between $3 500 and $47 200 in 2010, 4.95 per cent of annual earnings between $3 500 and $48 300 in 2011, and 4.95 per cent (5.025 per cent in Quebec) of annual earnings between $3 500 and $50 100 in 2012. Employees receive a non-refundable income tax credit for contributions made to EI and C/QPP. The federal credit was 15 per cent of contributions in 2012, 2011, 2010, 2009, 2008 and 2007; 15.25 per cent of contributions in 2006; 15 per cent of 77 contributions in 2005; 16 per cent of contributions in 2004, 2003, 2002 and 2001; and 17 per cent of the contributions in 2000. The federal credit rate for 2013 is 15 per cent. The provinces and territories also provide non-refundable income tax credits at rates that approximate their lowest personal income tax rate. III.1. CHILE a. Employee social security contributions classified as taxes In addition to the general contributions for health care, the following social contributions paid by minority groups in Chile are classified as taxes on the basis of the OECD Interpretive Guide Legacy contributions to public pension funds Contributions for health and pensions paid by the police Contributions for health and pensions paid by the army The upper limit thresholds in Chile are expressed in UF ( Unidad de Fomento ) which is a unit of account adjustable daily in line with the CPI. The upper limit threshold in each payment period represents 60 UF. b. Employee social security contributions classified as non-tax compulsory payments There are also a number of categories of contributions to private funds that are not classified as taxes.Chile has had a private pension system since January 1980 and a dual health system (both public and private health insurance) since 1981. Chilean employees pay the following mandatory contributions to private funds. 10% of gross earnings to finance retirement, disability and survivorship pensions. The payments are deposited in individual capitalization accounts managed by Pension Fund Administrators. An additional contribution, fixed by each Administrator, to finance the operations of the fund. A small group of employees who perform heavy work also pay a contribution equivalent to 2% of their gross earnings into their individual capitalization account. The National Ergonomic Commission can reduce the contribution rate from 2% to 1% when giving a “heavy” rating to a particular job. 7% of gross earning to contributions to private funds for health care. From October 2002, employees with 0.6% to the unemployed insurance, when the worker has an "indefinite term employment contracts”. Employees with "fixed-term employment contracts" do not have to contribute. The five mentioned contributions are subject to an upper threshold limit, which is adjusted yearly : 2009 and previous years Unemployment insurance Rest of the contributions 90 UF 60 UF 78 2010 97.1 UF 64.7 2011 99 UF 66 UF 2012 101.1 UF 67.4 UF 2013 105.4 UF 70.3 UF All the above contributions are deducted from taxable incomes. It is also possible to make additional voluntary contributions for pensions and health care. These are also deductible from taxable income except where the employee pays more than 4.921 UF for health care, or more than 50 UF per month or 600 UF per year for voluntary pension fund savings. III.1. CZECH REPUBLIC The rates of social security contributions for employees are: employee pension insurance contributions 6.5 % sickness insurance contributions 0% contributions to state employment policy 0% health insurance contributions Total 4.5 % 11 % III.1. GERMANY Part of the employee contributions is deductible (see description in country chapter of ‘Taxing Wages’). III.1. GREECE The great majority of individuals who are employed in the private sector and render dependent personal services are principally, directly and compulsorily insured in the Social Insurance Organisation (IKA). Apart from the main contribution, IKA compulsorily collects contributions for other minor Funds created for the employee’s benefit (Unemployment Benefits Funds, etc.). A subsidiary Social Insurance Fund (ETEAM) for employees who are principally insured in IKA has been also established since 1983. As regards the medical care, the National Organization for Healthcare Provision (EOPPY) was set up in 2011 with the Law 3918/11 art.17, absorbing the most important social security funds (IKA-ETAM, OGA, OAEE, OPAD) providing medical care for employees, self-employed, civil servants etc. The average rates of contributions payable by white-collar employees as a percentage of gross earnings are as follows (%) (Since 1-1-03): 1. Social Insurance Organisation (IKA) 2. Subsidiary Social Insurance Fund (ETEAM) 3. Other Funds Total Employer Employee Total 18.43 3.00 7.13 28.56 9.22 3.00 4.28 16.50 27.65 6.00 11.41 4.56 79 For blue-collar workers engaged in heavy work (unhealthy, dangerous etc), higher contributions are due (19.45% paid by the employee and 30.21% paid by the employer), so that such individuals become entitled to pension five years earlier than when the normal age limit applies. In the industrial sector, a contribution at a rate of 1 per cent is added as an occupational risk contribution which is paid by the employer, since the workers because of their difficult employment conditions are vulnerable to an increased risk of labour accidents and occupational diseases. So the effective total rate of a mixed insurance premium is 50.66% (employer’s contribution 31.21% and employee’s contribution 19.45%). Contributions are calculated as percentages on the basis of monthly salary or wages paid but within the limits specified in the National General Collective Employment Agreement. Monthly gross remuneration includes salaries and wages, fringe benefits and bonuses and any profit distributions to employees. A ceiling of €2,432.25 per month applies for individuals who have started working prior to 11-1993 (this cap is valid for the year 2012 and refers to the maximum amount of monthly wage for which contributions are paid). On the other hand, for individuals who have started working after 1-1-1993, the respective ceiling is €5,546.80 (for 2012). The contributions are fully deductible for income tax purposes. Note: The cap for the ‘old-insured’ in the monthly wage for which contributions are paid is calculated every year as follows: 25 x the highest day’s wage of the highest insurance class as provided for by the Law (art.37 of Law 1846/1951) i.e. 25 x 97.29 = 2,432.25. The cap for the ‘newly insured’ in the monthly wage for which contributions are paid is calculated every year as follows: 8 x average GDP per capita of 1991 adjusted for the State rate of increase in pensions of public servants i.e. 8 x 693.35 = 5546.80. III.1. ISRAEL Social security contributions paid by employees are made up of a combination of those for National Insurance and Health Insurance. 1. General background National insurance Every resident of Israel aged 18 and over is obligated by law to be insured by National Insurance and to pay the national insurance contributions. The National Insurance branches are made up of the following list; old age and survivors, long term care, general disability, accident and injury, work injury, maternity, children, unemployment and bankruptcy. Health insurance In addition, every resident is registered in one of the country’s health maintenance organisations ( HMO ). and must pay contributions for health insurance. The contributions are collected by the National Insurance Institute which distributes the moneys collected to the HMOs. The rates of contribution are calculated according to the work status and the level of the person’s income ( earned plus unearned ). A person who does not work and has no income (besides social benefits) pays a minimum amount depending on status (unless she is a married housewife who is totally exempt). Exemptions 80 There are exemptions from certain types of National Insurance contribution for some workers. For example, career soldiers are exempt from maternity insurance and foreign workers are exempt from national insurance contributions except for Work injury, Maternity and Bankruptcy. 2. Historical tax rates and thresholds A reduced rate applies up to a lower threshold of 50% the average wage per employee post (raised to 60% of the average wage per employee post in January 2006). The regular rate applies up to a upper threshold of around 5 times the average wage per employee post. The upper threshold was removed between July 2002 and June 2003. In July 2003 the upper threshold was re-instated at a level of 5 times the average wage per employee post. In August 2009 it was increased to 10 times the average wage per employee post, then, in January 2011, decreased to 9 times the average wage per employee post . In January 2012 the upper threshold was re-instated at a level of 5 times the average wage per employee post. The following table shows the historical tax rates and thresholds: Period Jan2000-Dec2000 Jan2001-Dec2001 Jan2002-Mar2002 Apr2002-Jun2002 Jul2002-Dec2002 Jan2003-Jun2003 Jul2003-Dec2005 Jan2006-Dec2006 Jan2007-Dec2007 Jan2008-Dec2008 Jan2009-Jul2009 Aug2009-Dec2009 Jan2010-Dec2010 Jan2011-Dec2011 Jan 2012-Dec2012 Jan2013-Dec2013 Reduced rate 5.76 5.76 5.76 5.76 5.76 4.5 4.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5 Lower threshold 3,174 3,482 3,525 3,482 3,482 3,482 3,482 4,430 4,522 4,598 4,757 4,757 4,809 4,984 5,171 5,297 Regular rate 9.7 9.7 9.7 9.7 9.7 10.32 10.38 12 12 12 12 12 12 12 12 12 Upper threshold 31,735 34,820 35,250 34,820 No limit No limit 34,820 35,760 35,760 36,760 38,415 76,830 79,750 73,422 41,850 42,435 The 2013 full and reduced rates for employee contributions and their breakdown into those applying to the Health insurance and the National Insurance branches are set out below. These figures have applied since the beginning of 2006. Branch Insurance branches Full rate Reduced rate contribution contribution (%) (%) 7.00 0.40 81 Health 5.00 3.10 Total contributions 12.00 3.50 III.1. LUXEMBOURG Since 2009, the SSC rates are equal for workers and employees. III.1. MEXICO Social security contributions paid by the employee are divided as follows: 1. For sickness and maternity insurance, 0.625 per cent of the employee’s monthly earnings, plus 0.40 per cent (1.68% in 2000; 1.52% in 2001; 1.36% in 2002; 1.20% in 2003; 1.04% in 2004; 0.88% in 2005, 0.72% in 2006, 0.56% in 2007 and 0.40% as of January 1, 2008)3 of his monthly earnings in excess of three times the monthly minimal wage in Mexico City ($64.76 pesos per day in 2013). These rates are applied over different bases, therefore, they cannot be added into a single rate. 2. For disability, and life insurance, 0.625 per cent of the employee’s monthly earnings for the 10 years reported. Employee’s monthly earnings include wages and fringe benefits such as food vouchers and housing benefits. For reporting purposes, the sickness and maternity insurance rates and the disability and life insurance rate were applied separately to the monthly wage, since a different ceiling to the salary base applies to these two contributions. Contributions to private retirement funds (AFORES) are not included in social security contributions. (See comment on Table I.1-I.4) Social security contributions paid by the employee are capped at $789 MXN in 2013 ($729 in 2000; $740 in 2001; $736 in 2002; $724 in 2003; $710 in 2004; $694 in 2005, $679 in 2006, $661 in 2007, $ 641 in 2008, $668 in 2009, $700 in 2010, and $729 in 2011 and $759 MXN in 2012) pesos per month for individuals earning an amount equivalent to 25 monthly minimum wages of the Mexico City ($64.76 pesos per day in 2013) or more. III.1 NETHERLANDS The social security contribution paid by employees consists of several parts: 1. Public insurance for medical care (social health plan). Public insurance for medical care has been reformed in 2006. A new standard health insurance system is introduced. Until 2005, no public health insurance contributions were levied on income in excess of EUR 33 000. However, taxpayers earning more than EUR 33 000 were obliged to take a private insurance. This was not included in the TW model. These private health insurance contributions were not included in the Taxing Wages calculations. In 2006, all individuals above the age of 18 years are obliged to insure themselves at a private insurance company and will be no part of the TW model. On average individuals 3 This rate decreased 0.16 percentage points on an annual basis. Starting in 2008 the applicable rate is 0.40 per cent. 82 pay a nominal premium to a private insurance company for the basic health insurance of (on average EUR 1,250 in year 2013) and in addition employers pay a percentage (7.75 per cent) of gross income net of employees’ pension premiums and unemployment social security contribution until a maximum of EUR 50,853. From 2013 this system has changed. Before, employees had to pay the contribution, and received a mandatory compensation of his employer for the same amount. This amount was included in the taxpayer’s taxable income and is part of the TW model. As stated above, from 2013 this is considered to be an employer’s contribution. This contribution of employers remains part of the non-tax compulsory payments (NTCP) and is used for equalizing health insurance risks between insurance companies. In the health insurance system competition is allowed between health insurance companies. Competition takes place under strict conditions of the government to avoid risk selection by the health insurance companies. The new standard private health system is quite similar to the old system before 2006 but it is now implemented by the private sector for all individuals and it allows more competition in the health care market. The health insurance contributions are now included in the calculations of the NTCP in the special feature of the Taxing Wages publication of 2009, but not in the standard publication of the Taxing Wages model. Taxpayers including self-employed might obtain compensation for the private nominal contribution of EUR 1,250, depending on the taxpayer’s personal situation and gross income. This is called the care benefit. The care benefit is calculated as follows for 2013: household of one adult : 1483 (med_adult for care benefit) – 2.195 per cent (med_compensation 1) * 18,509 (med_key) – 8.713 per cent (med_compensation 2) * (taxable income – 18,509 (med_key)). household of more than one adult: number of adults * 1483 (med_adult for care benefit) – 4.695 per cent (med_compensation 3) * 18,509 (med_key) – 8.713 per cent (med_compensation 4) * (taxable income – 18,509 (med_key)). 2. Unemployment scheme Employees pay a percentage of earnings between a threshold and a ceiling: From 2009, 0.0 percent In 2008, 3.5 per cent of gross earnings between EUR 15 921 and EUR 46 205 In 2007, 3.85 per cent of gross earnings between EUR 15 660 and EUR 45 017 In 2006, 5.2 per cent of gross earnings between EUR 15 138 and EUR 43 848 In 2005, 5.85 per cent of earnings between EUR 15 080 and EUR 43 587. In 2004, 5.8 per cent of earnings between EUR 15 196 and EUR 43 578. In 2003, 5.8 per cent of earnings between EUR 14 877 and EUR 43 065. In 2002, 4.95 per cent of earnings between EUR 14 486 and EUR 41 499. In 2001, 5.25 per cent of earnings between NLG 30 537 and NLG 87 957. 83 In 2000, 6.25 per cent of earnings between NLG 28 971 and NLG 83 259,3. 3 General scheme (Old age pensions, widows and orphans pensions, exceptional medical expenses and disability) The following premiums are levied from taxable income up to a ceiling (percentages 2013) Insurance percentage general old age pension 17.9% pension for widows and orphans 10.6% exceptional health care 12.65% Total 31.15% Total for taxpayers of 65 years and older 13.25% The ceiling of taxable income for these premiums is EUR 33,363 (2013). It is adapted to inflation every year The (wastable) tax credits also apply to contributions to general social security schemes. Taxpayers, older than 65 years do not pay premiums for general old age pension III.1. POLAND Social security contributions are paid monthly by employee (but calculated, collected and transfered to Social Security Institution (Zakład Ubezpieczeń Społecznych – ZUS) by employers) and can be divided into two groups: social insurance contributions – 13.71% of revenue as defined in Act on personal income tax (which is approximately the same as gross wage), in which: old-age pension insurance contribution - 9.76 % disability pension insurance contribution - 1.5 % % (from year 2008), 3,5 % (July 2007 – December 2007), 6,5 % (1999- June 2007), sickness insurance contribution - 2.45 %, health insurance contribution – base of its assessment is base of assessment for social insurance contribution minus employee’s contributions – rate was increased of 0.25% each year from 7.75 in year 2001 to 9% in 2007. This rate is still at present. 84 Employee’s social insurance contributions are fully deductible from taxable income, while health insurance contribution is deductible from tax but only at rate 7.75%. This rates can not be directly added because bases of their assessment are different. If the insured person is a member of the open pension fund (OPF), a part of the contribution to his or her old-age pension insurance is transferred by ZUS to OPF selected by the insured person. Since May 2011 the part of the contribution being transferred to OPF is reduced from the rate 7,3 % to 2,3 % of the basis of assessment. This rate is scheduled to increase gradually and reach: 2,8 % in 2013, 3,1 % in 2014, 3,3 % in 2015 and finally 3,5 % in 2017. Most people subject to social insurance accumulate their money for future pension in ZUS and a chosen OPF. However there is a small group of the insured that are not obliged to save their money in any OPF. These are: persons born before 1949, that are excluded form the new system of saving for pension and pay their contributions excluively to ZUS and will have their pension paid only from that source, persons born between 1949 and 1968, that could choose whether they wanted to pay their contributions solely to ZUS or also to OPF. The ceiling to contributions (old-age, disability) and pensionable earning is set at 2.5 times average earnings projected for a given year in the state budget law. It is 111 390 PLN in 2013. III.1. SLOVAK REPUBLIC There is both a minimum (only for full-time employees) and a maximum contribution, defined by the minimum base (the value given in the column for the lower threshold in the table) and the upper threshold. For 2000-2003, these amounts were fixed values. The upper thresholds for 2005 onwards are a function of the average wage, while the minimum base is equal to the minimum wage (see the table below). For 2004, the same system applied, but the 4% health contribution had a fixed minimum amount of 3,000 and upper threshold of 32,000. In 2008 there was a change of multiple (from 3 to 4) for calculation of upper threshold for social insurance (see the table). From 2011 onwards the change in upper thresholds were made (there is no change of upper thresholds during the year as from 2011, see the table below). As from 2013 maximum assessment bases for social and health security contributions has been increased and unified to 5 times the average wage (two years prior to when contribution is paid). 85 Rate Social Insurance 8% Sickness Insurance 1.4% Health Insurance 4% Rate Social Insurance 8% Sickness Insurance 1.4% Health Insurance 4% Rate All social insurance (9,4%) and health insurance (4%) Minimum base (lower threshold) Upper threshold 1.1-30.6 Upper threshold 1.7-31.12 Minimum monthly wage 4 times the average wage two years prior to when the contribution is paid 4 times the average wage in the year prior to when the contribution is paid Minimum monthly wage 1.5 times the average wage two years prior to when the contribution is paid 1.5 times the average wage in the year prior to when the contribution is paid Minimum monthly wage 3 times the average wage two years prior to when the contribution is paid Minimum base (lower threshold) Upper threshold 1.1-31.12 Minimum monthly wage 4 times the average wage two years prior to when the contribution is paid Minimum monthly wage 1.5 times the average wage two years prior to when the contribution is paid Minimum monthly wage 3 times the average wage two years prior to when the contribution is paid Minimum base (lower threshold) Minimum monthly wage Upper threshold 1.1-31.12 5 times the average wage two years prior to when the contribution is paid The latest amendment of the Minimum wage act (663/2007) adjusted date of the minimum wage indexation, which changed from October 1st to January 1st. After this amendment the effectiveness of the minimum wage is identical with calendar year as from 2009. From 1st January 2013 the minimum monthly wage is set at EUR 327.70. Period 1.10.2006 - 30.9.2007 1.10.2007 - 31.12.2008 1.1.2009 – 31.12.2009 1.1.2010 – 31.12.2010 1.1.2011 – 31.12.2011 1.1.2012 – 31.12.2012 1.1.2013 – 31.12.2013 Statutory minimum monthly wage The amount (in SKK) 7 600 8 100 8 900 - The amount (in Eur) 252.3* 268.9* 295.5 307.7 317.0 327.2 337.7 *calculated by conversion rate ( 1Eur = 30.126 SKK) 86 Compulsory contributions for 2004 onwards of 13.4 per cent of gross wages and salaries (with no limit) are paid by all employees into government operated schemes. The total is made up as follows: Health Insurance Social Insurance of which: 4.0 per cent 9.4 per cent Sickness Retirement Disability Unemployment 1.4 per cent 4.0 per cent 3.0 percent 1.0 per cent III.1. SLOVENIA The compulsory social security insurance system consists of four schemes as follows: pension and disability insurance; health insurance; unemployment insurance; maternity leave insurance. The taxable base for social security insurance contributions paid by employees is the total amount of the gross wage or salary including vacation payments, fringe benefits and remuneration of expenses related to work above a certain threshold. The assessment period is the calendar month. Employees contribute an amount as a percentage of their remuneration as follows. Scheme name Rate of contribution (%) Pension insurance 15.50 Health insurance 6.36 Unemployment insurance 0.14 Maternity leave 0.10 87 Total 22.10 III.1. SPAIN Social Security contributions are a fixed proportion of covered earnings between a floor and a ceiling, which vary by broadly defined professional categories. Currently, eleven categories are distinguished. For the first seven of them, floor and ceilings apply to monthly earnings. These floors and ceilings are shown below for the year 2013. They are approximately equal to, respectively, the professional minimum wage and three times the professional minimum wage. For the last four categories, floors and ceilings apply to daily earnings Professional Category Engineers and university graduates Qualified technicians and assistants Clerical and Workshop supervisors Non-qualified assistants Clerical Officers and Assistants Subordinates Administrative Assistants Workshop Officers Sub officers and Skilled workers Laborers Workers lower than 18 years old Minimum base 1,051.50 €/month 872.10 €/month 758.70 €/month 753.00 €/month 753.00 €/month 753.00 €/month 753.00 €/month 25.10 €/day 25.10 €/day 25.10 €/day 25.10 €/day Maximum base 3,425.70 €/month 3,425.70 €/month 3,425.70 €/month 3,425.70 €/month 3,425.70 €/month 3,425.70 €/month 3,425.70 €/month 114.19 €/day 114.19 €/day 114.19 €/day 114.19 €/day Social Security contributions made by taxpayers are addressed to cover the following contingencies: Common contingencies: illness, non-labour accidents, retirement, maternity leave, etc. Work injuries and professional diseases Overtime work Other contributions made for purposes such as: Unemployment Fund of Wage Guarantee Professional Training Social security contributions are calculated on the total monthly pay received by the employee, excluding per diem allowances and travel expenses, distance and transport supplements, petty cash allowances, work clothes and uniforms, death indemnities, relocation expenses and other minor items. As stated before, there is a minimum floor and a maximum ceiling or base for the first seven professional categories of employees (from engineers to administrative assistants; for the other four categories the minimum and maximum bases are computed on a daily basis). Social security bases are fixed every year by the General Budget Law. The tax rate is the percentage applied to the tax base. Tax rates are fixed every year by the General Budget Law. 88 For 2013 the rates applied for employers are the following: 89 Employers 23.60% 5.50% 6.70% 7.70% 0.20% 0.6% General Benefits Fund Unemployment (general rate) Unemployment (fixed duration – full time) Unemployment (fixed time – part time) Wage Guarantee Fund Professional Training III.1. SWEDEN The social security contribution paid by employees is based on the sum of earnings and taxable transfers. III.1. UNITED KINGDOM An employee aged 16 or over but below state pension age must pay primary Class 1 contributions unless earnings for the pay period for each employment are below the primary threshold (PT) in which case the payment is not made. Employees pay Class 1 contributions equal to 11 per cent of earnings above the PT (£110 per week in 2010-11) up to the upper earnings limit (UEL: £844 pw in 2010-11). Employees also pay contributions at 1 per cent above the UEL. There is a contracted out rebate of 1.6 per cent of earnings between the lower earnings limit (LEL, £97pw in 2010-11) and the upper accruals point (UAP) (£770 pw fixed from 2008-09 onwards)) for those in contracted-out salary related schemes and contracted-out money purchase schemes. No contributions are actually payable on earnings between LEL and PT but notional contributions are treated as having been paid to protect benefit entitlement. For appropriate personal pensions, the employer pays contributions at the standard not contracted-out rate and an age and earnings related rebate is paid directly to the personal pension provider at the end of the tax year. From 1981-82 the structure for employees’ contributions was as follows: Year Lower limit of earnings (£) Upper limit of earnings (£) 1981-82 1982-83 1983-84 1984-85 27.00 29.50 32.50 34.00 200 220 235 250 Not contracted-out rate payable on all earnings (%) 7.75 8.75 9.00 9.00 Contracted-out rate payable on all earnings (%) 5.25 6.25 6.85 6.85 The structure changed mid way through the year in 1985 so rates between October 1985 and April 1986 are not given in table III.1. They were as follows: Weekly income (£) 0-35.50 35.50-55 55-90 90-265 Employee’s contribution rate payable on all earnings (%) 0 5.00 7.00 9.00 The structure remained unchanged until October 1989 when it changed again mid way through the year. The rates that were applied between October 1989 and April 1990 are not given in table III.1 so are 90 given below. Weekly income (£) 0-43 43-325 Employee’s contribution rate (%) 0 2% on first £43; 9% on balance With the abolition of the 2 per cent entry fee on employee’s earnings below the lower earnings limit in April 1999 the structure changed to that below: Weekly income (£) 0-66 66-500 Employee’s contribution rate (%) 0 10.00 From 2003-04 the following structure was applied and has remained unchanged to date. Weekly income (£) 0- (PT) (PT) - (UEL) > (UEL) Employee’s contribution rate (%) 0 11.00 1.00 91 Part III, Table 2 III.2. AUSTRIA The SSC rates are for workers, and they are lower for other employees. They also include Contributions for the promotion of residential buildings (Payroll tax in ‘Revenue Statistics’), which are levied by health security institutions on the same base (but only on 12 current pays) as SSC. There is no lower threshold for accident insurance. Indeed, even for employees below the threshold, the employer may have to pay accident SSC. If the wage sum is above 150 per cent of the lower threshold, the employer has to pay health and pension contributions also for those employees below the lower threshold. III.2. BELGIUM The rate of the employer social security contribution listed in table III.2 is the sum of different items. Up to the third quarter of 1982 there were upper thresholds for some items. These thresholds were abolished starting from October 1982. On top of the marginal rate applicable to the gross salary, there was a lump sum to be paid from the third quarter of 1980 till the last of 1983. employer ssc Marginal rate in % of which lump sum upper treshold (BEF per quarter) pensi ons sickness allowances Unemployment Educational leave pensions sickness allowanc es Unemployment Educational leave firm closures 1980Q1 24,15 8 1,8 1,7 0,05 54150 54150 32750 32750 0 1980Q2 24,15 8 1,8 1,7 0,05 55225 55225 33400 33400 0 1980Q3 24,15 8 1,8 1,7 0,05 56325 56325 34075 34075 0 1980Q4 24,18 8 1,83 1,7 0,05 57450 70400 34750 34750 2215 1981Q1 24,12 8,86 1,84 1,27 0,05 71800 71800 71800 71800 2215 1981Q2 24,1 8,86 1,84 1,27 0,03 73225 73225 73225 73225 2215 1981Q3 24,1 8,86 1,84 1,27 0,03 73225 73225 73225 73225 2215 1981Q4 24,1 8,86 1,84 1,27 0,03 76200 76200 76200 76200 2215 1982Q1 24,07 8,86 2,1 1,23 0,03 95625 95625 95625 95625 2436 1982Q2 24,07 8,86 2,2 1,23 0,03 97525 97525 97525 97525 2436 1982Q3 24,09 8,86 2,2 1,23 0,05 99475 99475 99475 99475 2436 1982Q4 24,09 2436 1983Q1 24,07 2680 1983Q2 24,12 2680 1983Q3 24,07 2680 1983Q4 24,07 2680 92 From 1982 till 1999 some “Maribel”- reductions were granted, but not in all sectors of economic activity. Since 1999 these reductions were replaced by general “structural” reductions of employer social security contributions. The amount varies in relation to the gross salary following the tables below. As from 01.01.2013 Yearly gross salary (S) in € 0 < S < 23 600 23 600 < S < 49 939.20 S > 49 939.20 Yearly reduction in € 1 600 + 0.1620 (23 600 – S) 1 600 1 600 + 0.06 (S – 49 939.20) As from 01.04.2012 Yearly gross salary (S) in € 0 < S < 23 482.84 23 482.84 < S < 48 960 S > 48 960 Yearly reduction in € 1 600 + 0.1620 (23 482.84 – S) 1 600 1 600 + 0.06 (S – 48 960) As from 01.01.2012 Yearly gross salary (S) in € 0 < S < 23 482.84 23 482.84 < S < 48 000 S > 48 000 Yearly reduction in € 1 600 + 0.1620 (23 482.84 – S) 1 600 1 600 + 0.06 (S – 48 000) As from 01.01.2010 Yearly gross salary (S) in € 0 < S < 24 120.00 24 120.00 < S < 48 000 S > 48 000 Yearly reduction in € 1 600 + 0.1620 (24 120.00 – S) 1 600 1 600 + 0.06 (S – 48 000) As from 01.04.2007 Yearly gross salary (S) in € 0 < S < 23 482.84 23 482.84 < S < 48 000 S > 48 000 Yearly reduction in € 1 600 + 0.1620 (23 482.84 – S) 1 600 1 600 + 0.06 (S – 48 000) As from 01.01.2005 Yearly gross salary (S) in € 0 < S < 23 482.84 23 482.84 < S < 48 000 S > 48 000 Yearly reduction in € 1 600 + 0.1444 (23 482.84 – S) 1 600 1 600 + 0.06 (S – 48 000) 93 As of 01.01.2004 Yearly gross salary (S) in € 0 < S < 21 240 21 240 < S < 48 000 S > 48 000 Yearly reduction in € 1 600 + 0.1750 (21 240 – S) 1 600 1 600 + 0.0173 (S – 48 000) As of 01.04.2003 Yearly gross salary (S) in € 0 < S < 10 260.72 10 260.72 < S < 13 329.24 13 329.24 < S < 18 459.16 S > 18 459.16 Yearly reduction in € 1 390.36 2 945.56 2 945.56 - 0.3032 (S – 13 329.24) 1 390.36 As of 1.04.2002 Yearly gross salary (S) in € 0 < S < 10 260.72 10 260.72 < S < 13 329.24 13 329.24 < S < 18 459.16 S > 18 459.16 Yearly reduction in € 1 255.36 2 945.56 2 945.56 - 0.3295 (S – 13 329.24) 1 255.36 As of 1.04.2001 Yearly gross salary (S) in € 0 < S < 10 260.72 10 260.72 < S < 13 329.24 13 329.24 < S < 18 459.16 S > 18 459.16 Reduction in € 1 120.36 2 945.56 2 945.56 - 0.3558 (S - 13 329.24) 1 120.36 As of 1.04.2000 Yearly gross salary (S) in € 0 < S < 10 260.72 10 260.72 < S < 13 329.24 13 329.24 <S < 18 459.16 S > 18 459.16 Reduction in € 985.32 2 945.56 2 945.56 - 0.3821 (S - 13 329.24) 985.32 As of 1.04.1999 Yearly gross salary (S) in € 0 < S < 10 260.72 10 260.72 < S < 13 000.04 13 000.04 < S < 15 049.60 15 049.60 < S < 18 459.16 S > 18 459.16 Reduction in € 264.84 2 367.60 2 367.60 - 0.5509 (S – 13 000.04) 861.96 264.84 III.2. CANADA Starting in 2012, employer Quebec Pension Plan contributions are no longer harmonized with employer Canada Pension Plan contributions. In 2013, employer Canada Pension Plan contributions are 94 paid at a rate of 4.95 per cent and employer Quebec Pension Plan contributions are paid at a rate of 5.1 per cent. The contribution rate for both was 3.9 per cent in 2000; 4.3 per cent in 2001; 4.7 per cent in 2002; and 4.95 per cent in 2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011 and 2012 (except in Quebec in 2012, where the rate was 5.025 per cent). Contributions at the aforementioned rates are/were paid on employee earnings between $3 500 and $51 100 in 2013 ($37 600 in 2000, $38 300 in 2001, $39 100 in 2002, $39 900 in 2003, $40 500 in 2004, $41 100 in 2005, $42 100 in 2006, $43 700 in 2007, $44 900 in 2008, $46 300 in 2009, $47 200 in 2010, $48 300 in 2011 and 50,100 in 2012). Employer Employment Insurance contributions are 2.56 per cent of each employee’s annual earnings up to $47,400 in 2013. The comparable rates were 3.36 per cent in 2000, 3.15 per cent in 2001, 3.08 per cent in 2002, 2.94 per cent in 2003, 2.77 per cent in 2004, 2.73 per cent in 2005 and 2.62 per cent in 2006 of each employee’s annual earnings up to $39 000; 2.52 per cent in 2007 of each employee’s annual earnings up to $40 000; 2.42 per cent in 2008 of each employee’s annual earnings up to $41 000; 2.42 per cent in 2009 of each employee’s annual earnings up to $42 300; 2.42 per cent in 2010 of each employee’s annual earnings up to $43 200; 2.49 per cent in 2011 of each employee’s annual earnings up to $44 200; and 2.56 per cent in 2012 of each employee’s annual earnings up to $45 900. III.2. CHILE The main payments of employer social security contributions are not classified as taxes by the Ministry of Finance in Chile.. In Chile the upper limit earnings limit thresholds are expressed in UF [ Unidad de Fomento ] which is a unit of account adjustable daily in line with the CPI.( see notes to Table III.1 for further explanation). These payments are as follows: - Occupational accident and disease insurance; employers make a mandatory payment of 0.95% of the employee’s earnings subject to an upper earnings limit of 70.3 UF. In addition to this basic rate, there are further payments of up to an extra 3.4% in the case of riskier activities. For the majority of workers, these amounts are paid to employers’ associations of labour security which are private non-profit institutions. For the remainder the contributions are paid to the Social Security Regularisation Unit ( ISL ). Although this latter organisation is controlled by government the funds that are collected are invested on the private market. - Unemployment insurance; employers contribute 2.4% of an employee’s earnings ( 3% for fixed-term contracts ) subject to an upper earnings limit of 105.4 UF. These funds are managed privately. A premium to an Insurance Company to cover the worker in the event of disability or death, since July 2011. If the employee performs heavy work, the employer also pays a contribution equivalent to 2% of the worker gross earnings into his individual capitalization account. The National Ergonomic Commission can reduce the contribution rate from 2% to 1% when giving a “heavy” rating to a particular job. There are also some legacy pension contributions that are classified as taxes and the occupational accident and disease insurance payments that are paid to the ISL are presented as tax revenues in some Chilean documents. III.2. CZECH REPUBLIC The rates of social security contributions for employers are: 95 employer pension insurance contributions sickness insurance contributions 21.5 % 2.3 % contributions to state employment policy 1.2 % health insurance contributions Total 9% 34.0 % III.2. GREECE See explanatory note to Table III.1. III.2. IRELAND In 2002, the upper threshold was abolished hence no maximum contribution. III.2. ISRAEL The full amount of the employer contributions applies to the various National Insurance branches. Employers do not pay any contributions for health insurance on behalf of their employees. See the corresponding note for Table III.1 Employee social security contributions for the general background. Since July 2005 a reduced rate applies up to a lower threshold of 50% the average wage per employee post (raised to 60% of the average wage per employee post in January 2006). The regular rate applied up to a upper threshold of around 4 times the average wage per employee post until June 2002. The upper threshold was removed between July 2002 and June 2003. In July 2003 the upper threshold was reinstated at a level of 5 times the average wage per employee post. In August 2009 it was increased to 10 times the average wage per employee post. In January 2011 it was decreased to 9 times the average wage per employee post and back to 5 times the average wage per employee post in January 2012. The regular rate increased from 5.93% in 2012 to 6.5% in 2013 and will increase to 7.0% in 2014 and to 7.5% in 2015. The following table shows the historical tax rates and thresholds: Period Jan2000-Dec2000 Jan2001-Dec2001 Jan2002-Mar2002 Apr2002-Jun2002 Jul2002-Dec2002 Jan2003-Jun2003 Jul2003-Jun2005 Jul2005-Dec2005 Jan2006-Dec2006 Jan2007-Dec2007 Jan2008-Dec2008 Reduced rate 5.33 4.98 4.14 3.85 Lower threshold 3,482 4,430 4,522 4,598 Regular rate 4.93 4.93 4.93 4.93 5.93 5.93 5.93 5.68 5.68 5.68 5.43 Upper threshold 25,388 27,856 28,200 27,856 No limit No limit 34,820 34,820 35,760 35,760 36,760 96 Jan2009-Jul2009 Aug2009-Dec2009 Jan2010-Dec2010 Jan2011-Apr2011 Apr2011-Dec2011 Jan2012-Dec2012 Jan2013-Dec2013 3.45 3.85 3.85 3.85 3.45 3.45 3.45 4,757 4,757 4,809 4,984 4,984 5,171 5,297 5.43 5.43 5.43 5.43 5.90 5.90 6.5 38,415 76,830 79,750 73,422 73,422 41,850 42,435 III.2. LUXEMBOURG Since 2009, the SSC rates are equal for workers and employees. III.2. MEXICO Social security contributions paid by the employer are divided as follows: 1. Starting 2008 for sickness and maternity 20.40 per cent4 (15.2% in 2000, 15.85% in 2001, 16.5% in 2002, 17.15% in 2003, 17.80% in 2004, 18.45% in 2005, 19.10% in 2006 and 19.75% in 2007) of the monthly minimum wage in Mexico City per worker ($64.76 pesos per day in 2013), plus 1.10 per cent since 20085 (5.02% in 2000, 4.53% in 2001, 4.04% in 2002, 3.55% in 2003, 3.06% in 2004, 2.57% in 2005, 2.08% in 2006 and 1.59% in 2007) of the employee’s monthly earnings in excess of three times the monthly minimum wage in Mexico City, plus 1.75 per cent of the employee’s monthly earnings. 2. For disability and life insurance, 1.75 per cent of worker’s monthly earnings. 3. For social services and nursery, 1 per cent of worker’s monthly earnings. 4. Work injury contributions are a variable percentage of the worker’s monthly earnings. The amount depends on the risk level in which the company is classified. The weighted average risk premium is 1.98 per cent and it was calculated based on the information of every economic sector included in the AW estimation. Employee’s monthly earnings include wages and fringe benefits such as food vouchers and housing benefits. For reporting purposes, all rates applied over the employee’s monthly wage (with a single ceiling of 25 minimum wages of Mexico City starting in 2008) were added into a single rate of 6.48 per cent. Social security contributions paid by the employer are capped at $4.070 MXN in 2013 for employees earning an amount equivalent to 25 monthly minimum wages in Mexico City or more. They were capped at $4,080 in 2000, $4,240 in 2001, $4,322 pesos in 2002, $3,704 in 2003, $3,724 in 2004, $3,349 in 2005, $3,358 in 2006, $3,361 in 2007, $3,329 in 2008 $3,469 in 2009,3,637 in 2010, $3,787 in 2011 and $3,917 MXN in 2012. III.2. NETHERLANDS The social security contributions for employers: 4 This rate increased 0.65 percentage points on an annual basis. As from 2008, the applicable rate is 20.40 per cent 5 This rate decreased 0.49 percentage points on an annual basis. As from 2008, the applicable rate is 1.1 per cent. 97 1. Unemployment A percentage of the gross earnings between a threshold and a ceiling for the general unemployment fund. 1,70% between EUR 17,501 and EUR 50,853 in 2013 4.55% between EUR 17,229 and EUR 50,064 in 2012 4.20% between EUR 16,965 and EUR 49,297 in 2011 4.20% between EUR 16,704 and EUR 48,716 in 2010 4,15 per cent between EUR 16 443 and EUR 47 802 in 2009 4,75 per cent between EUR 15 921 and EUR 46 205 in 2008 4,40 per cent between EUR 15 660 and EUR 45 017 in 2007 3,45 per cent between EUR 15 138 and EUR 2.45 per cent between EUR 15 080 and EUR 43 587 in 2005 43 848 in 2006 1.55 per cent between EUR 15 196 and EUR 43 578 in 2004 1.55 per cent between EUR 14 877 and EUR 43 065 in 2003 3.6 per cent between EUR 14 486 and EUR 41 499 in 2002 3.65 per cent between NLG 30 537 and NLG 87 957 in 2001 - 3.75 per cent between NLG 28 972 and NLG 83 259 in 2000 A percentage of the gross earnings below a ceiling for the industrial insurance associations redundancy payments fund. 3,26 per cent of gross earnings below EUR 50,853 in 2013 2.77 per cent of gross earnings below EUR 50,064 in 2012 2.24 per cent of gross earnings below EUR 49,297 in 2011 1.82 per cent of gross earnings below EUR 48,716 in 2010 1.41 per cent of gross earnings below EUR 47 802 in 2009 1.36 per cent of gross earnings below EUR 46 205 in 2008 1.27 per cent of gross earnings below EUR 45 017 in 2007 1.48 per cent of gross earnings below EUR 43 848 in 2006 98 1.75 per cent of gross earnings below EUR 43 587 in 2005 1.89 per cent of gross earnings below EUR 43 578 in 2004 1.3 per cent of gross earnings below EUR 43 065 in 2003 0.89 per cent of gross earnings below EUR 41 499 in 2002 0.72 per cent of gross earnings below NLG 87 957 in 2001 1.05 per cent of gross earnings below NLG 83 259 in 2000 2. Invalidity A percentage of gross earnings below a ceiling. 5,19 per cent below EUR 50,853 in 2013 5.6 per cent below EUR 50,064 in 2012 5.72 per cent below EUR 49,297 in 2011 6.36 per cent below EUR 48,716 in 2010 6.32 per cent below EUR 47 802 in 2009 6.37 per cent below EUR 46 205 in 2008 6.38 per cent below EUR 45 017 in 2007 6.38 per cent below EUR 43 848 in 2006 7.25 per cent below EUR 43 587 in 2005 7.65 per cent below EUR 43 578 in 2004 7.4 per cent below EUR 43 065 in 2003 7.85 per cent below EUR 41 499 in 2002 7.7 per cent below NLG 87 957 in 2001 7.7 per cent below NLG 83 259 in 2000 3. Public insurance for medical care Public insurance for medical care has been reformed in 2006. A new standard health insurance system is introduced. In 2006, all individuals above the age of 18 years are obliged to insure themselves at a private insurance company. Individuals pay a nominal premium to a private insurance company for the basic health insurance of on average EUR 1,250 (in year 2013) and in addition employers pay a percentage (7.75 per cent) of gross income net of employees’ pension premiums and unemployment social security 99 contribution until a maximum of EUR 50,853 . This system has changed in 2013. Before, employees had to pay this income dependent contribution and were reimbursed for it by their employers. This reimbursement was added to the taxable income of the employee. III.2. NORWAY The rates are regionally differentiated according to five regional zones, with rates ranging from 0 in the northernmost part to 14.1 per cent in the most central areas. From July 1 2001 until December 31 2006 the employer’s SSC was reduced by 4 percentage points for most employees above 62 years (although not below zero). III.2. POLAND The rates of social security contributions for employers are: old-age pension insurance contribution - 9.76 % disability pension insurance contribiution - 6.5 % (from February 2012), 4,5 % (2008-January 2012), 6,5 % (1999-2007), work accident insurance contribiution (the rate varies across industries) - 0.4 % – 8.12% (rate used for calculation - 1.62%) contributions to Labour Fund - 2.45 % (from 1999), 3% (years 1993-1998), 2% (years 19901992), contribution to Benefits Guarantee Fund - 0.1% (from year 2006), 0.15% (years 2003-2005), 0.08% (years 1999-2002), 0.15% (1998), 0.18 (1997), 0.5% (from 1.03.1996 to 12.1996), 0.2% (from 1.03.1995 to 29.02.1996), 0.5% (from 2.04.1994 to 28.02.1995), 1% (from 1.01.1994 to 1.04.1994). Base of assessment of these contributions is revenue as defined in Act on personal income tax (which is approximately the same as gross wage). The ceiling to contributions (old-age, disability) and pensionable earning is set at 2.5 times average earnings projected for a given year in the state budget law. It is 11 390 PLN in 2013. The above describedd system concerning social insurance (i.e. old-age pension, disability pension and work accident insurance contributions) was introduced in 1999. Previously – the social contributions were paid only by employers, base of assessment of contributions was payroll and rates of contributions were: 45% (years 1990-1998), 38% (years 1987-1989), 33% (from 1.07.1982 to 31.12.1986), 25% (from 1.01.1981 – 30.06.1983). Contribution to Labour Fund (from1990) and Benefits Guarantee Fund (from1994) were also paid. III.2. SLOVAK REPUBLIC There is both a minimum (only for full-time employees) and a maximum contribution, defined by the minimum base (the value given in the column for the lower threshold in the table) and the upper threshold. The thresholds are the same as for employee social security contributions. See explanation to Table III.1 100 for further details. The same changes to upper thresholds are valid as for employees as from 2011and 2013 onwards. For the purposes of this table, the social insurance contribution rate for employers for 2005 onwards is assumed to be 25.2 per cent, in addition to a 10 per cent health insurance contribution. The social insurance rate reflects contributions to sickness insurance (1.4 per cent), disability insurance (3 per cent), retirement insurance (14 per cent), the Guarantee fund (0.25 per cent), accident insurance (0,8 per cent), for unemployment (1 percent) and to the Reserve fund (4.75 per cent). From January 2005, Slovakia has introduced the privately managed fully funded pillar. This means that a given proportion (9 percentage points) of social contributions paid by the employer for retirement insurance flows directly to the private pension funds and not to the Social insurance Agency as in previous years. As from September 2012 pension sharing scheme has been changed. Employer’s retirement contribution rate to the fully funded pillar (II .pillar) has been reduced from 9 per cent to 4 per cent (for more see pension contribution sharing table below).SSC: Pension - contribution sharing in case of II. pillar participation Percentage of gross earnings Period Previous system (up to September 2012) Current system (from September 2012)* I Pillar II Pillar 9% (5% employer + 4% employee contribution) 14% (10% employer + 4% employee contribution) 9% (employer contribution) 4% (employer contribution) Total 18% 18% * As from 2017 contribution rate to the II. pillar will automatically increase by 0.25 p.p. per year (i.e. contribution rate to the I. pillar will decrease in the same volume) III.2. SLOVENIA The compulsory social security insurance system consists of four schemes as follows: pension and disability insurance; health insurance; unemployment insurance; maternity leave insurance. The taxable base for social security insurance contributions paid by employers is the total amount of the gross wage or salary including vacation payments, fringe benefits and remuneration of expenses related to work above a certain threshold. The assessment period is the calendar month. Employers contribute an amount as a percentage of their remuneration as follows. Scheme name Rate of contribution (%) 101 Pension insurance 8.85 Health insurance 7.09 Unemployment insurance 0.06 Maternity leave 0.10 Total 16.10 III.2. SPAIN The tax rate is the percentage applied to the tax base. Tax rates are fixed every year by the General Budget Law. For 2013 the rates applied for employees are the following: General Benefits Fund Unemployment (general rate) Unemployment (fixed duration – full time) Unemployment (fixed time – part time) Wage Guarantee Fund Professional Training Employees 4.70% 1.55% 1.60% 1.60% 0.1% III.2. SWEDEN The employers’ social security contribution is based on the sum of wages and other payments for labour, including also sick pay paid by the employer. In certain regions, a reduction of 10 per cent of the base, maximum SEK 7 100 per month, is granted. On premiums for occupational pensions paid by the employer a reduced SSC rate (24.26 per cent) is applied. For employees under the age of 26 a reduced SSC rate of 15.49 per cent is applied. For employees who are over 65 years old and born after 1937 only the old age pension contribution (10.21 per cent) is applicable. For persons born in 1937 or earlier no employers’ social security contributions are applied. III.2. UNITED KINGDOM Employers pay Class 1 secondary contributions equal to 12.8 per cent of earnings above the secondary threshold (ST, £110 per week in 2010-11). There is a contracted-out rebate for secondary contributions of 3.7 per cent of earnings between the lower earnings limit (LEL, £97 pw in 2010-11) and the upper accruals point (UAP, £770 pw fixed from 2008-09 onwards) for contracted-out salary related schemes and 1.4 per cent for contracted-out money purchase schemes. An additional age-related rebate is paid directly to the scheme in the following tax year for money purchase schemes. For appropriate personal pensions and stakeholder pensions, the employer pays contributions at the standard not contracted-out rate and an age and earnings related rebate is paid directly to the personal pension provider in the following tax year. 102 From 1981-82 the structure for employer’s contributions was as follows: Lower limit of earnings (£) Year 1981-82 1982-83 1983-84 1984-85 27.00 29.50 32.50 34.00 Upper limit of earnings (£) 200 220 235 250 Not contracted-out rate payable on all earnings (%) 10.20 10.20 10.45 10.45 Contracted-out rate payable on all earnings (%) 5.70 5.70 6.35 6.35 The UEL for employer’s contributions was removed in 1985. The structure changed mid way through the year so rates between October 1985 and April 1986 are not given in table III.2. They were as follows. Weekly income (£) 0-35.50 35.50-55 55-90 90-130 > 130 Employer’s contribution rate payable on all earnings (%) 0 5.00 7.00 9.00 10.45 In addition national insurance surcharge (NIS) was payable by most employers (excluding charities) up to 1st October 1984 (6th April 1985 for local authorities). NIS was levied on employees’ gross earnings on exactly the same basis as employer’s NICs. The rates of NIS were 3.5 %, 2% and 1% from October 1978, August 1982 and April 1983 respectively. At the end of 1982-83 a rebate was made to employers. This reduced the effective rate of NIS for the year as a whole to 2 per cent. The structure changed in April 1999 when the multiple rates were replaced by a single rate charged above the secondary threshold. This structure has remained unchanged to date, but the rate has changed from 12.20 per cent in 1999-00, 11.9 per cent in 2001-02, 11.8 per cent in 2002-03 and increasing to 12.8 per cent from 2003-04 onwards. . III.2 UNITED STATES Starting in July 2011 the federal unemployment tax was reduced from 6.2 per cent to 6.0 per cent of wages up to USD 7 000. Taxes are also paid to various state-sponsored unemployment plans which are creditable against the federal tax (up to a maximum of 5.4 per cent of taxable wages). The federal tax rate 6.2 per cent of earnings up to USD 113,700 in 2013 for old age, survivors, and disability insurance and 1.45 percent of earnings without limit for old age hospital insurance. Part III, Table 3 III.3. AUSTRIA The table shows the rates for most self-employed. The rates are lower for farmers. Some groups (e.g. medical doctors, lawyers) have a different social security system, where the base is the (adjusted) taxable profits two years earlier. III.3. BELGIUM The social contribution is calculated on the inflation-adjusted net earned income realised three years before. There is a minimum and a maximum. Up to 2002 the income of the reference year was first grossed 103 up with the theoretical value of the social contribution due on such income according to the rate schedule of the reference year. Then this grossed up income was inflation adjusted and finally the social contribution was calculated (with a different marginal rate and additional fixed amount (lump sum) for each income bracket). From 2003 onwards, the marginal rates were increased but the grossing up and the additional fixed amounts were abolished. Contribution year (and reference year) 2013 (2010) 2012 (2009) 2011 (2008) 2010 (2007) 2009 (2006) 2008 (2005) 2007 (2004) 2006 (2003) 2005 (2002) 2004 (2001) 2003 (2000) 2002 (1999) 2001 (1998) 2000 (1997) Adjustment coefficient Minimum (euros; on yearly basis) Maximum (euros; on yearly basis) 1.0914513 1.0950350 1.0537941 1.0734670 1.0929874 1.0745475 1.0779395 1.0860889 1.0674172 1.0522912 1.0612037 1.0688421 (*) 1.0609871 (*) 1.0368237 (*) 2 822.72 2 771.44 2 668.56 2 601.36 2 601.36 2 512.49 1 924.32 1 899.08 1 837.20 1 781.88 1 753.62 1 721.11 1 689.57 (68 157 BEF) 1 635.47 (65 975 BEF) 15 905.30 15 616.25 15 036.50 14 657.95 14 657.95 14 157.17 12 607.56 12 422.28 12 036.76 11 674.20 11 489.17 11 251.91 10 716,70 (445 527 BEF) 10 692.69 (431 342 BEF) (*) applicable on grossed up income of the reference year III.3. CANADA In 2000, self-employed individuals received a non-refundable income tax credit of 17 per cent for contributions made to C/QPP. Effective from 2001, 50 per cent of contributions to C/QPP by self-employed individuals are deductible from income for purposes of determining taxable income. Self-employed individuals receive a non-refundable income tax credit for the other 50 per cent of contributions made to C/QPP. In 2004, 2003, 2002 and 2001 the federal credit was 16 per cent of the contributions eligible for the tax credit (i.e., the 50 per cent not deducted). In 2005 the federal credit was 15 per cent, in 2006 it was 15.25 per cent and in 2012, 2011, 2010, 2009, 2008 and 2007 it was 15 per cent of the eligible contributions. The federal credit rate for 2013 is 15 per cent. The provinces and territories also provide non-refundable income tax credits at rates which approximate their lowest personal income tax rate. Self-employed individuals generally do not contribute to EI. However, self-employed individuals can contribute to EI to access some special benefits. There are four types of EI special benefits for self-employed individuals: maternity benefits, parental benefits, sickness benefits and compassionate care benefits. The contribution rates and amounts are the same as those paid by employees. III.3. CHILE At present, the self-employed are not obligated to pay social security contributions. However they are able to make some types of contribution on a voluntary basis - health care; retirement pension; and insurance against employment accidents and occupational diseases using the same rates of contribution applicable to employees. These voluntary contributions are paid to the private sector and are therefore not classified as taxes. Looking to the future following the Law of Provisional Reform, promulgated on March 2008, the selfemployed will be liable to pay the contributions for retirement pension and insurance against employment 104 accidents and occupational diseases from 2012 (During 2012, 2013 and 2014 the self-employed can choose not to pay this contribution, but from 2015 it would be compulsory.), and the contributions for health care from 2018. The health care contributions paid to FONASA will be classified as tax revenues according to the OECD Interpretative Guide, but the other payments which will be made to private funds will not. III.3. CZECH REPUBLIC The rates of social security contributions for self-employed are: self-employed pension insurance contributions sickness insurance contributions 28 % Voluntary 2.3% ((increase from 1.4 contributions to state employment policy 1.2 % health insurance contributions Total 13.5 % 42.7 % %) For the year 2000-2003, the tax base for SSC of self-employed is 35% of their gross annual profit. Then the rate of 43.1% is applied (sum of social and health contributions rates, which is equal to the sum of percentages that employer and employee pay from employee’s gross wage but the sickness insurance is voluntary for self-employed and thus not classified as a tax). The effective rate is thus 15.09% in 20002003 (43.1% x 0.35). There is a cap of the base of 486 000 CZK. When the rate of 43.1% is applied to this threshold, the maximum contribution is 209 466 CZK. For 2004, the tax base for SSC of self-employed is 40% of their gross annual profit and it increased to 45% in 2005. The effective rates are thus 17.24 in 2004 (43.1% x 0.4) and 19.40% in 2005 (43.1% x 0.45). Since 2006 the tax base for SSC of self-employed is 50% of their gross annual profit. The effective rate is 21.55% in 2006 (43.1% x 0.5). The same effective rate is in 2007 and 2008. The effective rate for the year 2011 is 21,35% (42.7% x 0.5). III.3. GERMANY In the past, the self-employed people were not generally obliged to pay social security contributions. As from 1 January 2009, health insurance (including long-term care insurance) is mandatory for all citizens and permanent residents in Germany. The self-employed therefore need to be covered either by statutory health insurance or by private health insurance. Depending on certain conditions, their membership in statutory health insurance may be compulsory or voluntary. Otherwise, they have to contract with a private health insurance company. Furthermore, specific groups of self-employed are obliged to contribute to statutory pension insurance for at least 18 years (e. g. skilled craftsmen mandatorily organised in professional chambers). Members of the so-called ‘liberal professions’ (e. g. lawyers, physicians, engineers, architects) are compulsorily insured within special pension insurance schemes of the respective chambers they belong to. On certain conditions, self-employed artists and members of the publishing professions are obliged to pay contributions under the Artists Social Welfare Act, whereas farmers are mandatorily insured in the ‘Farmers’ Pension Fund’. III.3. GREECE Self-employed persons, such as craftsmen, retailers, professional motorists, hotel owners etc. are compulsory insured with the Social Security Organisation for the Self-Employed-“O.A.E.E.” which is a 105 fund that resulted from the merger of the former funds TEVE, TAE, TSA, TANPY, TPX and TPEAPI Fund. Certain other professional categories, such as medical personnel, doctors, pharmatists, engineers, lawyers, notaries etc. are compulsory insured with the Insurance Fund for Independent Professionals“ETAA”.Social security contributions to O.A.E.E. are not related to the level of gross earnings. Instead they are monthly charges depending on the years of insurance. There are fourteen (14) insurance categories and classification to the different existing insurance categories is automatically made and depends on the obligatory time spent in each one of them. The first 10 insurance categories are obligatory and the next 4 are optional. Starting 1.1.2007 onwards the fourteen insurance categories apply to all individuals regardless of the date they were first insured (before or after 1.1.1993). A newly insured individual is enrolled in the 1st class and every 3 years changes over to the next obligatory category. An individual can pay extra contribution if he wants (more than that required by his insurance category), by changing over to a higher category. In that case he has to petition. According to the insurance category the relevant contributions are calculated as following: The contribution for the pension branch is 20% of the category amount, paid by the insured, while especially for those first insured after 01/01/1993 the State contributes another 10% The contribution for the sickness branch is 7.65% of the category amount for those first insured after 01/01/1993 the State contributes another 3.8% of the category amount. The insured before 01/01/1993 contribute a flat rate of 92.79 euro, regardless of their insurance category Insurance categories of OAEE and the social security contributions that are based on them are illustrated in the table underneath: Insurance Category 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Category Amount as of 01/01/2011 762.04 930.71 1111.02 1212.92 1399.06 1577.93 1687.28 1824.48 1947.75 2071.08 2194.35 2317.62 2440.96 2564.24 Amounts of Contribution for Pension Branch (20%) 152.41 186.14 222.20 242.58 279.81 315.59 337.46 364.90 389.55 414.22 438.87 463.52 488.19 512.85 Amount of Contribution for Sickness Branch First insured after 1-11993 (7.65%) 58.30 71.20 84.99 92.79 107.03 120.71 129.08 139.57 149.00 158.44 167.87 177.30 186.73 196.16 First insured before 1-1-1993 92,79 92,79 92,79 92.79 92.79 92.79 92.79 92.79 92.79 92.79 92.79 92.79 92.79 92.79 106 Note: Categories valid from 1.1.2011 onwards according to Decree-Law 32/2011. Contributions for pension branch: 20% of the category amount; contributions for sickness branch: 7.65% of the category amount. III.3. IRELAND In 2002, the threshold only applies to the social insurance element (i.e., 5 per cent). III.3. ISRAEL Social security contributions for the self-employed are made up of a combination of those for National Insurance and Health Insurance. See the corresponding note for Table III.1 Employee social security contributions for the general background. A reduced rate applies up to a lower threshold of 50% the average wage per employee post (raised to 60% the average wage per employee post in January 2006). Until June 2002 the regular rate applied up to a upper threshold of around 4 times the average wage per employee post (and an extra rate applied between 4 times and 5 times the average wage per employee post) The upper threshold was removed between July 2002 and June 2003. In July 2003 the upper threshold was re-instated at a level of 5 times the average wage per employee post. In August 2009 it was increased to 10 times the average wage per employee post. In January 2011 and in January 2012 it was decreased to 9 times and then 5 times the average wage per employee post respectively. The following table shows the historical tax rates and thresholds: Period Jan2000-Dec2000 Jan2001-Dec2001 Jan2002-Mar2002 Apr2002-Jun2002 Jul2002-Dec2002 Jan2003-Jun2003 Jul2003-Dec2005 Jan2006-Dec2006 Jan2007-Dec2007 Jan2008-Dec2008 Jan2009-Jul2009 Aug2009-Dec2009 Jan2010-Dec2010 Jan2011-Dec2011 Jan2012-Dec2012 Jan2013-Dec2013 Reduced Lower rate threshold 8.82 3,174 8.82 3,482 8.82 3,525 8.82 3,482 9.82 3,482 9.82 3,482 9.82 3,482 9.82 4,430 9.82 4,522 9.82 4,598 9.82 4,757 9.82 4,757 9.82 4,809 9.82 4,984 9.82 5,171 9.82 5,297 Regular rate 14.42 14.42 14.42 14.42 15.42 15.42 15.42 16.23 16.23 16.23 16.23 16.23 16.23 16.23 16.23 16.23 Upper threshold 25,388 27,856 28,200 27,856 No limit No limit 34,820 35,760 35,760 36,760 38,415 76,830 79,750 73,422 41,850 42,435 Extra rate 9.55 9.55 9.55 9.55 Additional threshold 31,735 34,820 35,250 34,820 The 2031 full and reduced rate of contributions for the self-employed and their breakdown into those applying to the Health insurance and the National Insurance branches are set out below. These figures have applied since the beginning of 2006. 107 Branch Full rate Reduced rate contribution contribution (%) (%) Insurance branches 11.23 6.72 Health 5.00 3.10 Total contributions 16.23 9.82 III.3. ITALY Self-employed workers register in public bodies (about sixteen) involved to collect and manage social contributions. There are different bodies for different types of activity (commercial experts, land surveyors, engineers, physicians, journalists, lawyers, actors, chemists etc.). Each body fixes the minimum charge to be paid by the member and the rates to be applied to his declared gross taxable income. Among these bodies INPS (Istituto Nazionale di Previdenza Sociale) counts the largest number of registered workers who belong to the categories of artisans and traders. Social security contributions vary with age and with the level of taxable business income as illustrated in the following table. Furthermore, for employees who have begun to pay contributions after the 1995 the maximum contribution undergoes an increase of about 30%. Year 2000 2001 2002 2003 2004 Taxable income 0 - £ 22,688,224 £ 22,688,224 - £ 66,324,000 £66,324,001 - £ 110,540.000 £ 110,540,000 and over 0 - £ 22,243,896 £ 22,243,896 - £ 68,048,000 £68,048,001 - £ 113,413,333 £ 113,413,333 and over 0 - € 12,312.00 € 12,312.00 - € 36,093.00 € 36,093.01 - € 60,155.00 € 60,155.00 and over 0 - € 12,590.00 € 12,590.00 - € 36,659.00 € 36,659.01 - € 61,598.00 € 61,598.00 and over 0 - € 12,889.00 € 12,889.00 - € 37,883.00 € 37,883.01 - € 63,138.00 € 63,138.00 and over Artisans Under 21 years Over 21 years £ 3,009,845 £ 3,692,210 13.20 % 16.20 % 14.20 % 17.20 % £ 15,048,439 £ 18,366,358 £ 3,129,682 £ 3,826,,500 13.40 % 16.40 % 14.40 % 17.40 % £ 15,666,040 £ 19,067,941 € 1,681.87 € 2,051.28 13.60 % 16.60 % 14.60 % 17.60 % € 8,429.14 € 10,233.84 € 1,744.86 € 2,122.56 13.80 % 16.80 % 14.80 % 17.80 % € 8,754.35 € 10,602.29 € 1,811.95 € 2,198.62 14.00 % 17.00 % 15.00 % 18.00 % € 9,099.36 € 10,993.50 Traders Under 21 years Over 21 years £ 3,098,329 £ 3,780,694 13.59 % 16.59 % 14.59 % 17.59 % £ 15,479,545 £ 18,797,463 £ 3,199,414 £ 3,896,232 13.70 % 16.70 % 14.70 17.70 % £ 16,006,280 £ 19,408,181 € 1,729.89 € 2,099.25 13.99 % 16.99 % 14.99 % 17.99 % € 8,663.75 € 10,468.40 € 1,793.96 € 2,171.64 14.19 % 17.19% 15.19 % 18.19 % € 8,994.59 € 10,842.51 € 1,862.22 € 1,991.11 14.39 % 17.39% 15.39 % 18.39 % € 9,093.05 € 10,981.96 108 0 - € 13,133.00 € 13,133.00 - € 38,641.00 € 38,641.00 - € 64,402.00 € 64,402.00 and over 0 - € 13,345.00 € 13,345.00 - € 39,297.00 € 39,297.00 - € 65,495.00 € 65,495.00 and over 0 - € 13,598.00 € 13,598.00 - € 40,083.00 € 40,083.00 - € 66,805.00 € 66,805.00 and over 0 - € 13,819.00 € 13,819.00 - € 40,765.00 € 40,765.00 - € 67,942.00 € 67,942.00 and over 0 - € 14,240.00 € 14,240.00 - € 42,069.00 € 42,069.00 - € 70,115.00 € 70,115.00 and over 0 - € 14,334.00 € 14,334.00- € 42,364.00 € 42,364.00 - € 70,607.00 € 70,607.00 and over 0 - € 14,552.00 € 14,552.00- € 43,042.00 € 43,042.00 - € 71,737.00 € 71,737.00 and over 0 - € 14,930.00 € 14,930.00- € 44,204.00 € 44,204.00 - € 73,673.00 € 73,673.00 and over 0 - € 15,357.00 € 15,357.00- € 45,530.00 € 45,530.00 - € 75,883.00 € 73,883.00 and over 2005 2006 2007 2008 2009 2010 2011 2012 2013 € 1,864.89 14.20 % 15.20 % € 9,402.69 € 1,921.68 14.40 % 15.40 % € 9,693.26 € 2,243.67 16.50 % 17.50 % € 11,290,05 € 2,349.23 17.00 % 18.00 % € 11,821.91 € 2,428.24 17.00 % 18.00 % € 12,200.00 € 2,444.22 17.00 % 18.00 % € 12,285.62 € 2,481.28 17.00 % 18.00 % € 12,482.24 € 2,739.63 18.30 % 19.30 % € 13,776.85 € 2,886.88 18.75% 19.75 % € 15,531.59 € 2,258.88 17.20 % 18.20 % € 11,334.75 € 2,322.03 17.40 % 18.40 % € 11,658.11 € 2,651.61 19.50 % 20.50 % € 13,294.20 € 2,763.80 20.00 % 21.00 % € 13,860.17 € 2,855.44 20.00 % 21.00 % € 14,303.46 € 2,874.24 20.00 % 21.00 % € 14,403.83 € 2,917.84 20.00 % 21.00 % € 14,634.35 € 3,187.53 21.30 % 22.30 % € 15,987.09 € 3,347.59 21.75 % 22.75 % € 16,808.08 € 1,916.10 14.59 % 15.59 % € 9,653.86 € 1,973.73 14.79 % 15.79 % € 9,948.69 € 2,255.91 16.59 % 17.59 % € 11,350.17 € 2,361.66 17.09 % 18.09 % € 11,883.00 € 2,441.06 17.09 % 18.09 % € 12,263.11 € 2,457.12 17.09 % 18.09 % € 12,349.17 € 2,494.38 17.09 % 18.09 % € 12,546.80 € 2,753.07 18.39 % 19.39 % € 13,843.15 € 2,900.70 18.84 % 19.84 % € 15,599.89 € 2,310.09 17.59% 18.59 % € 11,585.92 € 2,374.08 17.79% 18.79 % € 11,913.54 € 2,663.85 19.59% 20.59 % € 13,354.32 € 2,776.24 20.09% 21.09 % € 13,921.32 € 2,868.26 20.09% 21.09 % € 14,366.56 € 2,887.14 20.09% 21.09 % € 14,467.38 € 2,930.94 20.09% 21.09 % € 14,698.91 € 3,200.96 21.39 % 22.39 % € 16,053.34 € 3,361.41 21.84 % 22.84 % € 16,876.38 III.3. KOREA Since the medical insurance premium of the self-employed is charged in the fixed amount depending on their income and properties, the medical insurance premium is not assessed on the basis of rate. So, the medical insurance premium is not included in the marginal rate of self-employed social securities contribution rates shown in the table. The national pension rate of the self-employed will be increased gradually from 3 per cent to 9 per cent during the period 2000-2005. III.3. MEXICO Self-employed individuals have 2 voluntary options: either to comply with the general regime or to pay only for the family health insurance. 1. In the first case, the individual will pay for sickness, maternity, disability and life insurance. The contribution is a fixed rate based on the annual minimum legal wage in Mexico City. The following table summarises these payments. 109 Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Types of insurance Sickness and maternity Disability and life $2,334.3 $349.8 $2,538.5 $365.4 $2,732.4 $378.4 $2,939.2 $392.2 $3,151.6 $405.7 $3,393.0 $421.9 $3,645.5 $438.4 $3,915.9 $455.9 $4,080.4 $475.0 $4,278.5 $498.1 $4,454.2 $518.6 $4,641.1 $540.3 $4,822.0 $561.4 Total $2,684.1 $2,903.9 $3,110.8 $3,331.4 $3,557.3 $3,814.9 $4,083.9 $4,371.8 $4,555.4 $4,776.6 $4,972.8 $5,181.4 $5,383.4 Fixed Annual Fee (Mexican pesos) The base in all cases is equal to the annual minimum wage in Mexico City ($64.76 pesos per day in 2013). In this option the family of the individual receives the covered social security benefits under this regime. The self-employed must in this case also pay for the retirement, discharge and old age insurance; however these contributions are not included since they are privately managed (AFORES). 2. Under the second option (the family health insurance option), individuals must pay a fixed annual fee that depends on the number and age of the family members as of 2002: Year 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Fixed annual fee in pesos by age category 0 to 19 20 to 39 40 to 59 60 or more $889 $1,039 $1,553 $2,337 $940 $1,098 $1,642 $2,470 $977 $1,142 $1,707 $2,568 $1,028 $1,201 $1,796 $2,701 $1,062 $1,241 $1,856 $2,791 $1,105 $1,291 $1,931 $2,904 $1,147 $1,340 $2,004 $3,013 $1,222 $1,427 $2,135 $3,210 $1,266 $1,478 $2,211 $3,325 $1,322 $1,543 $2,308 $3,471 $1,372 $1,602 $2,396 $3,604 $1,421 $1,659 $2,481 $3,733 Each relative must pay the corresponding annual fee in accordance to the age group he/she belongs to. For OECD Tax Database purposes, this annual fee was calculated for the average Mexican family that consists of the self-employed worker, his spouse and two children. In 2001 and 2000 the Social Security Law applied a different methodology for the estimation of this second option of family health insurance: the annual fee was 22.4 per cent of the annual minimum wage in Mexico City, and each additional relative paid 65 per cent of the previous amount. A third option can be applied. Under this option an individual who has made at least 52 weekly contributions to the social security system during the previous five years and leaves his/her job can maintain the insurance as long as he/she continues paying her contributions according to the last salary base. 110 III.3. NDS Social security contributions by self-employed: 1. Invalidity In august 2004 invalidity contributions by self-employed people was abolished. Self-employed people designated to private insurance companies. In 2000-2003, it was calculated as a percentage (8.8 per cent) of gross earnings (profits) between a threshold (EUR 13 160 for 2002 and 2003, equivalent to NLG 29 000 in 2000 and 2001) and a ceiling (EUR 38 118 for 2002 and 2003, equivalent NLG 84 000 in 2000 and 2001). 2. Public insurance for medical care (social health plan). Public insurance for medical care has been reformed in 2006. A new standard health insurance system was introduced (see Part III Table 1). From 2006, all individuals above the age of 18 years are obliged to insure themselves at a private insurance company. This system is also applicable to self-employed. Individuals pay a nominal premium to a private insurance company for the basic health insurance of on average EUR 1,250 (in 2013). In addition self-employed pay an income depended contribution of percentage (5,65 per cent) (i.e 2,10 per cent lower than the employer contribution fot his/her employee) of taxable profits until a maximum of EUR 50853. Taxpayers including self-employed might obtain compensation for the private nominal contribution of EUR 1,250, depending on the taxpayer’s personal situation and gross income. This is called the care benefit. The care benefit is calculated as follows for 2013: household of one adult : 1483 (med_adult for care benefit) – 2.195 per cent (med_compensation 1) * 18,509 (med_key) – 8.713 per cent (med_compensation 2) * (taxable income – 18,509 (med_key)). household of more than one adult: number of adults * 1483 (med_adult for care benefit) – 4.695 per cent (med_compensation 3) * 18,509 (med_key) – 8.713 per cent (med_compensation 4) * (taxable income – 18,509 (med_key)). III.3. NORWAY The social security contribution rate for the self-employed is 11 per cent of gross labour income (including imputed labour income) from 2008 onwards. For self-employed in primary industries (agriculture, forestry and fisheries) the SSC rate is 7.8 per cent on all gross labour income. III.3. POLAND Polish social security system (applying to self-employed) consists of: social insurance system, health insurance, 111 Labour Fund. Social insurance system covers: old-age pension insurance, disability and survivors’ pension insurance, insurance in respect of sickness and maternity (called sickness insurance), insurance in respect of accidents at work and occupational diseases (called work accident insurance). The health insurance is a system of benefits of the preventive, diagnostic, therapeutical and rehabilitation character, provision of medicines as well as orthopaedic appliances and auxiliary means, financed by public means. Labour Fund finances different forms of counteracting unemployment and mitigating its effects, it pays the unemployment benefit. In Poland two systems of social insurence exist– for farmers and for non- farmers. The system of social insurance of farmers is financed by contributions payable by farmers and from the state budget allocation. III.3. PORTUGAL 1. Self-employed social contributions base corresponds to the monthly conventional gross earnings. Beneficiaries have to choose the value of conventional earnings (from 1.5 times up to 12 times the value of the national minimum wage). 2. There is a compulsory flat rate of 29.6%. 3. The lower limit corresponds to 1.5 times the value of the Social Benefits Index (SBI) and the higher limit corresponds to twelve times the SBI. The maximum contribution is equal to 29.6 per cent x 12 x SBI) and annual incomes up to 12 times the value of the SBI are exempt. However, when the annual gross income is lower than 18 times the national minimum wage it is possible to ask annually for the application of a base corresponding to one twelfth of the annual gross income, with a minimum of 50% of the SBI. III.3. SLOVAK REPUBLIC There is both a minimum and a maximum contribution, defined by the minimum base (the value given in the column for the lower threshold in the table) and the upper threshold. As from 2010 the minimum base is defined as 44.2% of average wage in national economy two years prior to when the contribution is paid. The upper thresholds are the same as for employee social security contribution. Social insurance assessment base for the self-employed is defined as half of their tax base (before tax allowances) in previous year. Health insurance assessment base is defined as the tax base (before allowances) in previous year plus paid health contributions, divided by 2.14. As from 2013 minimum assessment base for social security of self employees has been increased, 112 social security contribution will be no longer deducted from their assessment base for social security contribution and the calculation of the assessment base for social security has been changed as well. Minimum base has been increased to 50% of average wage in national economy two years prior to when the contribution is paid. Social insurance assessment base is defined as the tax base (before tax allowances) in previous year plus paid social contributions, divided by 1.9. Health insurance assessment base is defined as the tax base (before allowances) in previous year plus paid health contributions, divided by 1.9. It has been also legislated that both formulas for calculation of assessment bases will change in denumerator from 1.9 in 2013 to 1.458 in 2015 (in 2014 it would be 1.6). Self-employed are obliged to pay social insurance in the current year (year t), if their previous year’s turnover (in year t-1) was higher than 12 x minimum assessment base. Obligation to pay these contributions for self employed starts from 1st July in the current year (year t). Health insurance contributions have to be paid by every self-employed person. III.3. SLOVENIA The compulsory social security insurance system consists of four schemes as follows: pension and disability insurance; health insurance; unemployment insurance; maternity leave insurance. Self-employed individuals-insured persons are obliged to pay social security contributions (SSC) on the basis of their profits (ie taxable profits minus net tax allowances). The amounts are assessed by applying the following contribution rates. Scheme name Rate of contribution (%) Pension insurance 24.35 Health insurance 13.45 Unemployment insurance 0.20 Maternity leave 0.20 Total 38.20 113 There is an SSC base schedule (social security insurance base) which defines the insurance (contribution) base with regard to the amount of the profit (e. taxable profits minus net tax allowances). The basis for payments in a given year is calculated on the basis of the profits made in the previous year. The table below describes how the basis for SSC payments in 2013 is calculated based on the profits made in 2012. In the schedule there is defined minimum and maximum insurance (contribution) base. Between 2000 and 2013, the minimum insurance base is defined by the annual minimum wage (a weighted total of the pre and post August monthly levels). If the self-employed person makes a loss or a profit that is less than the annual minimum wage, the base is equal to the minimum wage. If the profit is for example between annual minimum wage and annual average wage in Slovenia (AAW), the SSC insurance base is at least at the amount of 60% of the AW. The base is set at higher levels for profit levels higher than the average annual wage (AAW) as is described in the table. Since August 2005 and all the year 2013, the maximum insurance (contribution) base has been defined as the amount of 240% of the AW when the profit level exceeds 350% of the AAW. Prior to August 2005 the maximum contribution base was defined as the maximum pension base grossed up by average annual rate of taxes and contributions. Since 2014 the SSC base will be determined differently - according to the profits made in previous year, that is reduced by 25 % (no more sorting into insurance classes). If the self-employed person will create a loss or a profit (reduced by 25 %) that is less than the 60 % of the AW, the base will be equal to the 60 % of the AW. The maximum insurance (contribution) base will be defined as the amount of 350 % of the AW. Self-employed individuals can opt to pay their SSC at a higher insurance (contribution) base than the one calculated on the basis of their profit but no higher than the amount equal to 240% of the AW. When the insurance (contribution) base is determined, the contributions are paid monthly from the insurance (contribution) base applicable in the current period. For example, when the profit in 2012 has been assessed to be between minimum and average wage, the SSC in 2013 is paid from the SSC base equal to 60% of the average wage of the pre-previous month. This means that, for example, the average wage for April is used to calculate the SSC base for June. The average wage is published each month and there is no consolidation of payments on an annual basis. INSURANCE BASE IN 2013 PROFIT THRESHOLD (2012) INSURANCE (contribution) BASE (2013) Classification of the insurance base depending on the level of profit Lower threshold Upper threshold Minimum wage Over Up to 9.156,72 Minimum wage 9.156,72 114 Minimum wage Average wage (AW) 9.156,72 18.305,64 60% of AW of the one but pre-previous month 10.983,38 Average wage (AW) 150% of AW 18.305,65 27.458,46 90% of AW of the one but pre- previous month 16.475,00 150% of AW 200% of AW 27.458,46 36.611,28 120% of AW of the one but pre-previous month 21.966,77 200% of AW 250% of AW 36.611,28 45.764,10 150% of AW of the one but pre- previous month 27.458,46 250% of AW 300% of AW 45.764,10 54.916,92 180% of AW of the one but pre-previous month 32.950,15 300% of AW 350% of AW 54.916,92 64.069,74 210% of AW of the one but pre-previous month 38.441,84 240% of AW of the one but pre-previous month 43.933,54 350% of AW 64.069,74 *Data in Table are shown on the annual base in Euros.. III.3. SPAIN Self-employed Social Security Contributions are subject to a flat SSC rate applied to monthly earnings situated between a floor and a ceiling base according to following table applied in 2013. Selfemployed may opt for a reduced SSC rate in which case they are not entitled to perceive benefits in case of sickness. Minimum base 858.20 €/month Maximum base 3,425.70 €/month Contribution base for those 47 years old in 01/01/2012 Self-employed workers who in December 2012, with a contribution base over 1,870.50 €/month or just enrolled in this scheme may choose a contribution base between 858,20 and 3,425.70 euros/month If the last contribution base is lower than 1,870.50 euros/month they may not choose a contribution base over 1,888.80 euros/month, unless they change their contribution base before June 30th, with effect from July 1, 2013. 115 If the last contribution base was less than or equal to 1,870.50 euros/month, they may choose a base between 858.60 and 1,888.80 euros/month If the last contribution base is greater than or Contribution base for those over 50 years old equal to 1,870.50 euros/month, they may choose a with 5 years or more of contributions base between 858.60 euros/month and that amount increased by 1 percent, until a base 1,888.80 euros/month. In general, the contribution base will be situated between 925.80 and 1,888.80 Contribution base for those aged 48 or over in euros/month. 01/01/2012 29.80% SSC rate (including temporary incapacity) 29.30% in case of cessation of activity SSC rate (no temporary incapacity) 26.50% III.3. SWEDEN Social security contributions of the self-employed are based on total labour income. In certain regions, a reduction of 10 per cent of the base, maximum SEK 18 000 per year, is granted. The self-employed can opt for a reduced rate in which case they will receive less generous sick pay. On premiums for occupational pensions paid by the employer a reduced SSC rate (24.26 per cent) is applied. For selfemployed under the age of 26 a reduced SSC rate of 14.88 per cent is applied. For self-employed who are over 65 years old and born after 1937 only the old age pension contribution (10.21 per cent) is applicable. For self-employed persons born in 1937 or earlier no social security contributions are applied. Self employed aged between 26 and 64 are entitled to a reduction of their social security contributions with 5 percentage points, up to a maximum of SEK 10 000 per year. III.3. TURKEY In the calculation of the premium paid by the self-employed people, an income scale with twenty-four steps is used. In this scale, the indicator is calculated by multiplying the indicator of each step with the civil servant’s wage bracket (it is increased twice a year in January and in July.) 20% of this amount is paid as monthly premium (contribution) and 20% of it is paid as health premium (the health premium of the first eight steps is the same as the health premium of the eighth step). The income steps in the income scale are determined in April by being increased at first according to the last base year urban places consumer prices index change rate announced by State Institute of Statistics in respect of the December of the last year and the December of the previous year, secondly according to the development rate of gross domestic product of last year with constant prices. This income scale does not have a connection or a proportion with the real income of the self-employed and the at the beginning the insured person chooses what he likes from the 116 first twelve steps of this income steps. Up to the first twelve steps, steps are taken automatically, but from the twelfth step to the twenty-fourth steps are taken bi annual in case the insured person so demands. III.3. UNITED KINGDOM Self-employed individuals pay two distinct categories of contributions: Class 2 contributions are flat-rate payments (£2.40 pw in 2009-10) payable by all self-employed people over 16 unless they have applied for the small earnings exception (£5 075 per annum in 2009-10). Class 4 contributions are earnings-related payments which are paid if profits exceed a lower threshold. They are a percentage rate of the earnings (8 per cent) between the Upper Profits Limit (UPL - £43 875 in 2009-10) and Lower Profits Limit (LPL - £5 715 in 2009-10) limits. Profits above the UPL contribute at a rate of 1 per cent. 117