Page 61 - Mazars Central and Eastern European tax guide 2023

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 Transfer pricing documentation liability Other comments and recent developments

(years)

Tax exemption for 4 and 5-star hotels for a time frame
Exempted / of ten years; 5% CIT for software and IT development,
Albania ü No ü ü No 3/5 ü
0% / 15% automotive industry and agritourism industry
(for the first 10 years).

No From 2023: allowance for certain investments of 10%
Austria 24% No ü ü ü ü limitation period ü (15% for ecological investments) of the acquisition
costs – cap of EUR 1 million p.a.
BH (Fed.) 10% / 0% ü ü ü ü ü 5 ü -

BH (Rep.) 10% / 0% No No No 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
(but for corporate 5 years ü
Czech Republic 19% income tax, No ü ü ü (and loss carry-back (optional but DAC 6 mandatory disclosure requirements.
Czech Accounting for 2 years) recommended)
Standards apply)

Estonia No 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 carry back.
Germany 15% (~30%*) ü ü ü ü No limitation period ü *Together with trade tax.
Abolishment of solidarity tax as of 1 January, 2023,
Greece 22% ü No ü ü ü 5 ü extension of low VAT to transport, coffee, non-alcoholic
beverages, gyms, dance schools, films and tourism
packages up to June 2023.

Hungary 9% ü ü ü No ü 5 ü No WHT on dividend, royalties and interest payments.
ATAD regulations implemented.
Since 2023, limits on the deduction of intercompany/
intra-group expenses where introduced. Since 2023,
Kazakhstan 20% ü No ü ü No 10 ü participation exemption rule 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
Kosovo 10% / 9% / 3% No No No ü No 4 ü been reduced from 6 to 4 years. The basis and rate
of taxation of insurance companies has changed from
a 5% tax on gross premiums to a 10% tax on income.
Since 2023 Sales Tax at the rate of 1-2% is applied to all
Kyrgyzstan 10% ü No No ü No 5 No types of sales on top of VAT. Before 2023 it did not
apply to sales paid via bank transfer. In some cases 0%
Sales Tax can be applied.
*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.

60 Mazars Central and Eastern European tax guide 2023 Central and Eastern European tax guide 2023 Mazars 61