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Cit Key Features

2024 Corporate income tax rate(s) IFRS accounting available (for all companies) Group taxation available Interest limitation (Thin Cap or EDITDA based) Witholdig tax on interest, dividend or royalty R&D /patent box incentive Loss carry-forward (years) Transfer pricing documentation liability Other comments and recent developments
Albania 5% / 15% 5  
Austria 23% No limitation period allowance for certain investments equal to 10% (15% for ecological investments) of acquisition costs – cap of EUR 1 million p.a.
BH (Fed.) 10%/0% 5  
BH (Rep.) 10%/0% 5 0% for small taxpayers in Republika Srpska.
Bulgaria 10% 5 TP local file is obligatory for companies above a threshold defined by the law.
Croatia 18%/10% 5  
Czech Republic 21%
(but for CIT, Czech Accounting Standards apply)
5 years (and loss carry-back for 2 years)
(optional but recommended)

DAC 6 mandatory disclosure requirements. DAC 7 rules implemented.
Estonia 20/80 or 14/86 CIT is paid only on the distributed dividends: lower rate 14/86, standard rate 20/80
Germany 15% (~30%*) No limitation period Loss carry back.
*Together with trade tax
Greece 22% 5 Tax-free threshold increased €1,000 for taxpayers with children, business tax (L.3986/2011) reduced 50% for self-empoyed, amendments on short-term leases, VAT for hosts leasing ≥3 properties.
Hungary 9% 5 No WHT on dividend, royalties, and interest payments. ATAD regulations implemented.
Kazakhstan 20% 10 Since 2023, a participation exemption rule under which dividends payable to shareholders and non-residents owning shares for more than 3 years was cancelled.
Kosovo 10%/9%/3% 4 The loss carry forward period for tax losses has 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.
Kyrgyzstan 10% 5
Latvia 20%* *The tax base of CIT divided by 0.8 and then multiplied by 20%, which means that the effective CIT rate is 25% of the taxable base.
Lithuania 15%/5% No, however losses can be transferred to another group entity No limitation period
except local transactions
0% rate for small companies for the first financial year.
Moldova 12% N/A 5    
Montenegro Progressive tax rate set between 9% and 15% depending on realized profits 5  
North Macedonia 10%
(large and mid-sized entities)
3 The Transfer Prices Report Rulebook was recently introduced.
Poland 9%/ 19% (basic rates) 5 Changes in the so-called Estonian CIT; changes in WHT; changes to the so-called bad debt relief; repeal of provisions on so-called hidden dividends; so-called minimum tax (effective from 2024).
Romania 16% 5 Tax consolidation rules.
Serbia 15% 5  
Slovakia 15%/21% 5 Exit tax; Participation exemption rules; ATAD (incl. hybrid mismatch) rules; Country-by-Country (CbC) Reporting; DAC 6 and DAC 7 mandatory disclosure requirements.
Slovenia 22% No limitation period General limitation of tax base reduction for tax periods after January 1, 2020, resulting in setting a minimum corporate tax rate of 7%. Exit taxation applies as of January 1, 2020.
Ukraine 18%
no limitation period with exception for large taxpayers
There is a beneficial tax and a legal regime called DiiaCity for IT companies and start-ups.
Uzbekistan 15% No limits  Since April 2024 taxpayers with high a rating may enjoy some tax benefits. Rating is automatically defined based on many factors.