Page 63 - Mazars Central and Eastern European tax guide 2023

Corporate income tax key features

Corporate income tax rate(s) lFRS accounting available (for all companies) 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

Group

No, however, (years)
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.

Moldova 12% ü No ü ü N/A 5 ü -

Progressive tax
rate set between At the end of FY2021, several changes were
Montenegro 9% and 15% ü ü No ü No 5 ü implemented to the CIT Law, as stated above, with
depending implementation from FY2022 onwards.
on realized
profits.
ü
North Macedonia 10% (large and No ü ü No 3 ü The Transfer Prices Report Rulebook was recently
mid-sized entities) introduced.
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 of provisions on so-called hidden dividends;
minimum tax.

Romania 16% No ü ü ü ü 7 ü Tax consolidation rules are introduced.

Serbia 15% ü ü ü ü ü 5 ü –

Exit tax; Participation exemption rules;
Slovakia 15% / 21% No No ü ü ü 5 ü Country-by-Country (CbC) Reporting;
CFC rules applicable for companies and natural
persons; ATAD (incl. hybrid mismatch) rules.
General limitation of tax base reduction for tax periods
No
Slovenia 19% ü No ü ü ü ü after 1 January 2020, resulting in setting a minimum
limitation period corporate tax rate of 7%. As of 1 January 2020,
exit taxation applies.
Yes (no limitation
period except for
Ukraine 18% ü No ü ü No large taxpayers) ü There is a beneficial tax and legal regime Diia City for
IT companies and start-ups.

Transfer pricing regulation came into effect only from
Uzbekistan 15% ü No ü ü No No limits ü 2022 and 2023 is the 1st year of reporting. The VAT rate
has decreased from 15% to 12% since 2023.

62 Mazars Central and Eastern European tax guide 2023 Central and Eastern European tax guide 2023 Mazars 63