Page 65 - CEE Tax Guide 2025

Corporate income tax rate(s) IFRS accounting available (for all companies) Group taxation available Interest limitation (Thin Cap or EBITDA based) Withholding tax on interest, dividend or royalty R&D/patent box incentive Loss carry- forward (years) Transfer pricing documentation liability Other comments and recent developements

Albania 5% / 15% No No 5 No
Austria 23% No unlimited Not applicable.
Bosnia and Herzegovina (FBiH) 10% / 0% 5 –

Bosnia and Herzegovina (RS) 10% / 0% No No 5 0% for small taxpayers in Republika Srpska.
Bulgaria 10% No 5 TP local file is obligatory for companies above a threshold
defined by the law.
Croatia 18% / 10% No 5 In December 2022, the United States (US) and Croatia signed
a Double Taxation Treaty (DTT), which will take effect once both
nations have completed and exchanged notifications of their
required domestic procedures. Additionally, Croatia signed a DTT
with Saudi Arabia in December 2024; however, this agreement
has not yet come into effect. Meanwhile, new agreements with
Hong Kong, Andorra, Cyprus, and Egypt have been ratified and
are in force.
Czech Republic 21% (but Czech No 5 years (optional DAC 6 mandatory disclosure requirements.
Accounting Standards (and loss but recommended) DAC 7 rules implemented.
apply for CIT) carry-back
for 2 years)
Estonia 22/78 No No No From January 1, 2025, the Motor Vehicle Tax Act entered into
force. Motor vehicle tax (car tax) is a national tax paid by all owners
or authorised users of motor vehicles registered in the motor
register. Motor vehicle tax is paid for a calendar year, paid by owner
or authorised user and administered by the Estonian Tax and
Customs Board. Registration fee is paid upon first registration.
Germany 15.825% plus No (permitted limit No Indefinite - Sophisticated anti-abuse provisions,
14% trade tax / of net interest - withholding tax obligations need to be thoroughly observed,
on average (~30%*) expenses of 3m EUR) possible tax reform under new government.

Greece 22% No 5 N/A
Hungary 9% No 5 N/A
Kazakhstan 20% No No 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% No No No No 6 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% No No No 5 No No

Latvia 20%* No No No No *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 16% / 6% No; however, losses No limitation except for local 0% rate for small Companies for the first financial year.
can be transferred period. transactions. Deductions for passenger car purchases and rentals are now
to another limited based on the vehicle’s CO emissions, with specific caps set
2
group entity. according to emission levels.
Moldova 12% No N/A 5 –

Central and Eastern European tax guide 2025 Forvis Mazars 65