Under the new CIT model in force as of 1 January 2018, all undistributed corporate profits are exempt. This exemption covers both active (e.g. trading) and passive (e.g. dividends, interest, royalties) types of income. It also covers capital gains arising on the
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There is broad support for measures to reform the transfer pricing, permanent establishment and diverted profits tax rules. Respondents to the consultation on UK law reform of the transfer pricing, permanent establishment and diverted profits tax rules launched in 2023 broadly agree
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Resident companies are generally taxed on their worldwide income. A permanent establishment (PE), e.g. a branch of a company, is taxed on profits attributable to the PE. Non-resident companies are taxable on Jersey real estate income. Companies are liable to income tax
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Applicable rates Italian corporate entities are subject to a corporate income tax, known as imposta sul reddito sulle società or IRES, and to a regional production tax, known as imposta regionale sulle attività produttive or IRAP. The standard rates are as follows: Up to FY 2016,
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Corporation tax is chargeable as follows on income and capital gains: Standard rate on income(‘trading rate’) Higher rate on income(‘passive rate’) Capital gains rate 12.5% 25% 33% Resident companies are taxable in Ireland on their worldwide profits (including gains). Non-resident companies are
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Resident corporations are liable to tax on their worldwide income. Non-resident corporations are subject to Guernsey tax on their Guernsey-source income. Companies pay income tax at the current standard rate of 0% on taxable income; however, income derived from certain businesses may
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Resident corporations are taxed on their worldwide income. Non-resident corporations are taxed in Greece on any Greek-source income they derive therein. For the tax year 2021 onwards, the corporate income tax (CIT) rate of legal entities, with the exemption of credit institutions,
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Companies are subject to Gibraltar taxation on income accrued in and derived from Gibraltar. The standard corporate income tax (CIT) rate is 12.5% (increasing from 10% with effect from 1 August 2021), with utility and energy providers and companies that abuse a
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Germany taxes its corporate residents on their worldwide income. However, most double tax treaties (DTTs) exempt income attributable to a foreign permanent establishment (PE). Non-residents with PE or property income are taxed by assessment on German-source income; those earning royalties and dividends
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Companies are subject to tax on all income and are only allowed deductions on expenses that are related to the operations of the company. According to Danish tax law, a territoriality principle prevails with respect to PEs and real estate located abroad.
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