Page 64 - CEE Tax Guide 2024

Pillar 2 implementation

Was the Council Directive (EU) 2022/2523 implemented into the local legislation? Did the local legislation implement IIR? Did the local legislation implement UTPR? Did the local legislation implement QDMTT? What tax types qualify as covered taxes under the GloBE rules? Does the local law include any significant difference compared to the Directive? Was the Council Directive (EU) 2022/2523 implemented int

New Law effective from Kazakhstan N/A N/A N/A N/A N/A
Albania ü ü ü ü N/A January 2024 is partially No
aligned with the Directive.

Austria ü ü ü ü Corporate income tax No Kosovo No N/A N/A N/A Corporate Income Tax 5%
(Körperschaftsteuer)

BH (Fed.) No N/A N/A N/A N/A N/A Kyrgyzstan No N/A N/A N/A N/A N/A

BH (Rep.) No N/A N/A N/A N/A N/A Latvia No N/A N/A N/A N/A N/A

The covered taxes
of a constituent entity shall Lithuania No N/A N/A N/A N/A N/A
extend to:
1. the expenses charged for taxes
with respect to the profit and
income of the constituent entity; Moldova No N/A N/A N/A N/A N/A
a tax upon profit distribution
or what qualifies as such,
Bulgaria ü ü ü ü as well as a tax on non-business No Montenegro No N/A N/A N/A N/A N/A
expenses under an eligible
profit distribution tax system;
alternative taxes imposed
instead of corporate tax;
a tax on retained earnings and North Macedonia ü ü ü ü – –
equity, including on multiple
components based on profit,
income, and equity.
Poland No N/A N/A N/A N/A N/A
There is no distinction between
Croatia ü ü ü ü local law and the provisions No
Romania must notify
Corporate Income Tax or any
of the Directive.
substitute, taxes on distributed the EC of the election
Taxes reported in the profits, payments qualifying of the QDMTT within
4 months following the
as profit distributions, and
entity's financial statements Romania ü ü ü ü non-business expenses, taxes adoption of the domestic
Czech Republic ü ü ü ü based on its income or profit, No on retained earnings and law, meaning by end
i.e. CIT including capital gain
tax, windfall tax, and adjusted corporate equity. of April 2024.
deferred tax.
Serbia No N/A N/A N/A N/A N/A
Estonia No N/A N/A N/A N/A N/A
No, but the option for the
national supplementary tax Tax declared in financial
Corporate and trade tax as well was taken, which applies Slovakia ü No No ü statements of constituent entity No
Germany ü ü ü ü as the solidarity surcharge, if domestic business units in relation to its income (profit).
capital gains tax. of a foreign group are
subject to an effective tax
of less than 15%.
Slovenia ü ü ü ü Income tax No
Greece No N/A N/A N/A N/A N/A

Hungarian legislation Ukraine No N/A N/A N/A N/A N/A
allows taxpayers
Corporate income tax, local
to compute their GloBE
Hungary ü ü ü ü business tax, innovation tax liability based on the
contribution, Robin Hood tax.
Hungarian Accounting Uzbekistan No N/A N/A N/A N/A N/A
Standards.

64 Mazars Central and Eastern European tax guide 2024 Central and Eastern European tax guide 2024 Mazars 65