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Worldwide Tax Summaries Corporate Taxes 2017/18 www.pwc.com/taxsummaries Worldwide Tax Summaries Corporate Taxes 2017/18 Quick access to information about corporate tax systems in 157 countries worldwide. Central Asia and Eastern Europe Worldwide Tax Summaries Corporate Taxes 2017/18 All information in this book, unless otherwise stated, is up to date as of 1 June 2017. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors. © 2017 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details. Foreword Welcome to the 2017/18 edition of Worldwide Tax Summaries – Corporate Taxes, one of the most comprehensive tax guides available. This year’s edition provides detailed information on corporate tax rates and rules in 157 countries worldwide. As governments across the globe are Some of the enhanced features available looking for greater transparency and online include Quick Charts to compare with the increase of cross-border rates across jurisdictions. You may also activities, tax professionals often need access WWTS content through Tax access to the current tax rates and other Analysts at www.taxnotes.com. major tax law features in a wide range of countries. The country summaries, If you have any questions, or need more written by our local PwC tax specialists, detailed advice on any aspect of tax, include recent changes in tax legislation please get in touch with us. The PwC tax as well as key information about income network has member firms throughout taxes, residency, income determination, the world, and our specialist networks deductions, group taxation, credits and can provide both domestic and cross- incentives, withholding taxes, indirect border perspectives on today’s critical taxes, and tax administration. All tax challenges. information in this book, unless otherwise stated, is up to date as of 1 June 2017. Our online version of the summaries is available at www.pwc.com/taxsummaries. The Worldwide Tax Summaries (WWTS) website also covers the taxation of individuals and is fully mobile compatible, Colm Kelly giving you quick and easy access to Global Tax & regularly updated information anytime on Legal Services Leader your mobile device. PwC Ireland www.pwc.com/taxsummaries Foreword 1 Contents Foreword ...............................................1 Country chapters Afghanistan, Islamic Republic of ............4 Albania ................................................11 Armenia ..............................................23 Azerbaijan ...........................................42 Belarus ................................................59 Bosnia and Herzegovina ......................85 Bulgaria ............................................ 110 Croatia ..............................................129 Georgia .............................................150 Kazakhstan ........................................164 Kosovo ..............................................179 Kyrgyzstan ......................................... 191 Macedonia ........................................205 Moldova ............................................ 218 Montenegro ......................................241 Poland ...............................................253 Romania ............................................279 Russian Federation ............................ 314 Serbia ................................................339 Turkey ...............................................352 Turkmenistan ....................................378 Ukraine .............................................388 Uzbekistan, Republic of ..................... 416 Worldwide Tax Summaries Editorial Team ...................................432 2 Contents PwC Worldwide Tax Summaries Country chapters Central Asia and Eastern Europe Afghanistan, Islamic Republic of PwC contact Mirza Taqi-Ud-Din Ahmad A.F. Ferguson & Co., Chartered Accountants (a member firm of the PwC network) P.I.A. Building 49 Blue Area Fazl-ul-Haq Road Islamabad, Punjab 44000 Pakistan Tel: +92 51 227 3457-60 Email: [email protected] Significant developments There have been no significant corporate tax developments in Afghanistan during the past year. Taxes on corporate income A resident company is taxed on its worldwide income. A non-resident company is taxed on its Afghan-source income only. The corporate income tax (CIT) rate in Afghanistan is 20% of the taxable income in a fiscal year. No income tax is required to be paid by a legal person in case of loss during a fiscal year. However, one will be required to pay business receipt tax (BRT) even if one suffers loss during the fiscal year (see Business receipt tax in the Other taxes section). All receipts of corporations and limited liability companies (LLCs) as reduced by exemptions and deductions allowed under prevailing tax law are treated as income of such corporations or LLCs. Every company that, without a business licence or contrary to approved by-laws, provides supplies, materials, construction, and services under contract to government agencies, municipalities, state entities, private entities, and other persons shall be subject to 7% fixed tax in lieu of income tax. This tax is withheld from the gross amount. Corporate residence A legal person will be considered a ‘resident’ for a tax year if it has been established in Afghanistan or the centre of its administrative management is in Afghanistan at any time during the year. Permanent establishment (PE) Taxation of income is not dependent on PE; any income from an Afghanistan source by a non-resident person shall be taxable in Afghanistan at the rate of 20%. A foreign corporation or LLC is considered doing business in Afghanistan if it has a place of business in Afghanistan. A foreign company shall not be considered doing www.pwc.com/taxsummaries Afghanistan, Islamic Republic of 4 Afghanistan, Islamic Republic of business in Afghanistan if its sales are to a broker, an independent dealer, an agency of the state, etc. If the foreign corporation or LLC is doing business in Afghanistan, its income from such business is taxable in Afghanistan. Place of business is defined as the place in which the business of the enterprise is wholly or partly carried on. Other taxes Value-added tax (VAT) There is no VAT in Afghanistan. Business receipt tax (BRT) BRT is a tax that is collected from total gross income (sales) before any deduction according to prescribed rates. BRT is imposed on the business activities of companies and corporations as follows: • 4% of the gross receipts (before any deductions) during the fiscal year from any business activities pertaining to provision of goods and services in exchange for consideration. • 4% of the gross receipts (before any deductions) during the fiscal year from hotels or guest houses and restaurants where quarterly less than 750,000 Afghani (AFN). • 5% of the gross receipts (before any deductions) during the fiscal year from services provided by clubs and halls where events are held. • 5% of the gross receipts (before any deductions) during the fiscal year from hotels or guest houses and restaurants where quarterly income is more than the threshold limit of AFN 750,000. • 10% of the gross receipts (before any deductions) during the fiscal year from hotel services and restaurant services providing premium services, communication services, and airline services. BRT is an allowable deduction in the computation of taxable income. Although there is no express exemption from payment of BRT to organisations that are exempted from income tax under the prevailing tax provisions of tax law, in practice such exemption is granted at the time of issuance of private ruling along with corporate tax exemption. Customs duties Every person with a valid business licence who imports any goods in Afghanistan is subject to a fixed tax at the rate of 2% of the total cost including customs duty payable on the import of such goods. The amount of income tax so paid is adjustable against the income tax payable by such person. Where the goods are imported by a person who do not have a business licence issued by the Afghanistan Investment Support Agency (AISA) / Ministry of Commerce (MoC), the income tax at the rate of 3% of the total cost including customs duty shall be payable in lieu of final income tax at the time of import of goods. 5 Afghanistan, Islamic Republic of PwC Worldwide Tax Summaries Afghanistan, Islamic Republic of Excise taxes There are no excise taxes in Afghanistan. Property taxes There are no property taxes in Afghanistan. Transfer taxes There are no transfer taxes in Afghanistan. Stamp taxes There are no stamp taxes in Afghanistan. Payroll taxes Employers are not responsible to pay any other tax in respect of their employees or their salaries. Branch income The rates of tax for a branch of a company incorporated outside of Afghanistan are the same as those applicable on resident companies. Where a company carries on business in Afghanistan through a branch office, the taxable income of the branch is determined as if the branch is a separate legal person. The following should also be considered in computing taxable income of a branch in Afghanistan: • Payments or amounts incurred to another part of the non-resident person are deemed as dividends. • Expenses incurred by the branch or another part of the non-resident person that related directly to the earning of gross income by the branch are
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