Page 63 - 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 EDITDA 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

Moldova 12% ü No ü ü N/A 5 ü –

Progressive tax
rate set between
Montenegro 9% and 15% ü ü No ü No 5 ü –
depending
on realized
profits.
ü
North Macedonia 10% (large and No ü ü No 3 ü The Transfer Prices Report Rulebook was recently
mid-sized
introduced.
entities)
Changes in the so-called Estonian CIT; changes
Poland 9%/ 19% No ü ü ü ü 5 ü in WHT; changes to the so-called bad debt relief; repeal
(basic rates) of provisions on so-called hidden dividends; so-called
minimum tax (effective from 2024).

Romania 16% No ü ü ü ü 5 ü Tax consolidation rules.

Serbia 15% ü ü ü ü ü 5 ü –

Exit tax; Participation exemption rules; ATAD (incl.
Slovakia 15% / 21% No No ü ü ü 5 ü hybrid mismatch) rules; Country-by-Country (CbC)
Reporting; DAC 6 and DAC 7 mandatory disclosure
requirements.
General limitation of tax base reduction for tax periods
No
Slovenia 22% ü No ü ü ü limitation period ü after January 1, 2020, resulting in setting a minimum
corporate tax rate of 7%. Exit taxation applies
as of January 1, 2020.
Yes (no limitation
Ukraine 18% ü No ü ü No period except for ü There is a beneficial tax and a legal regime called
large taxpayers) DiiaCity for IT companies and start-ups.
Since April 2024 taxpayers with high a rating may enjoy
Uzbekistan 15% ü No ü ü No No limits ü some tax benefits. Rating is automatically defined
based on many factors.

62 Mazars Central and Eastern European tax guide 2024 Central and Eastern European tax guide 2024 Mazars 63