Page 61 - CEE Tax Guide 2024

Corporate income tax key features

Corporate income tax rate(s) lFRS accounting available (for all companies) Group taxation available Interest limitation (Thin Cap or EBITDA based) Withholding tax on interest, dividend or royalty R&D / patent box incentive Loss carry-forward (years) Transfer pricing documentation liability Other comments and recent developments

Albania 5% / 15% ü No ü ü No 5 ü –

No allowance for certain investments equal to 10%
Austria 23% No ü ü ü ü limitation period ü (15% for ecological investments) of acquisition costs –
cap of EUR 1 million p.a.
BH (Fed.) 10% / 0% ü ü ü ü ü 5 ü –

BH (Rep.) 10% / 0% ü No ü ü No 5 ü 0% for small taxpayers in Republika Srpska.

Bulgaria 10% ü No ü ü No 5 ü TP local file is obligatory for companies above
a threshold defined by the law.

Croatia 18% / 10% ü No ü ü ü 5 ü –
ü 5 years
(but for CIT, ü DAC 6 mandatory disclosure requirements.
Czech Republic 21% Czech Accounting No ü ü ü (and loss carry-back (optional but DAC 7 rules implemented.
Standards apply) for 2 years) recommended)

Estonia 20/80 or 14/86 ü No No ü No ü ü CIT is paid only on the distributed dividends: lower rate
14/86, standard rate 20/80.

No
Loss carryback
Germany 15% (~30%*) ü ü ü ü No limitation period ü *Together with trade tax.
Tax-free threshold increased EUR 1,000 for taxpayers
Greece 22% ü No ü ü ü 5 ü with children, business tax (L.3986/2011) reduced
50% for self-employed, amendments on short-term
leases, VAT for hosts leasing ≥3 properties.

Hungary 9% ü ü ü No ü 5 ü No WHT on dividend, royalties, and interest payments.
ATAD regulations implemented.
Since 2023, a participation exemption rule
Kazakhstan 20% ü No ü ü No 10 ü under which dividends payable to shareholders
and non-residents owning shares for more than
3 years was cancelled.
The loss carry forward period for tax losses has
been reduced from 6 to 4 years. The basis and rate
Kosovo 10% / 9% / 3% No No No ü No 4 ü of taxation of insurance companies has changed from
a 5% tax on gross premiums to a 10% tax on income.

Kyrgyzstan 10% ü No No ü No 5 No No

*The tax base of CIT divided by 0.8 and then multiplied
Latvia 20%* ü No ü No No No ü by 20%, which means that the effective CIT rate is 25%
of the taxable base.
No; however,
losses can ü
Lithuania 15% / 5% ü be transferred ü ü ü No except for local 0% rate for small Companies for the first financial year.
to another limitation period transactions.
group entity.

60 Mazars Central and Eastern European tax guide 2024 Central and Eastern European tax guide 2024 Mazars 61