Page 67 - 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

Montenegro Progressive tax rate No 5 New incentives have been introduced in relation to R&D activities
set between 9% / and investments in agricultural projects.
12% / 15% depending
on realized profits.
North Macedonia 10% (large and mid- No No 3 The Transfer Prices Report Rulebook was recently introduced.
sized entities)
Poland 9% / 19% (basic rates) No 5 Introduction of JPK CIT (new SAF-T standard control files for CIT
and fixed assets in the required format), first to report JPK CIT
for the tax year beginning after December 31, 2024 (for entities
with an annual turnover of EUR 50 million per year), introduction
of a global equalization tax which applies to certain Polish CIT
taxpaying companies and tax capital groups whose effective tax
rate is less than 15%.
Romania 16% No 5 Tax consolidation rules.
Serbia 15% 5 No new developments from a CIT standpoint comapred to the
previous year.
Slovakia 10% / 15% / 21% / 24% No No 5 Exit tax; Participation exemption rules; ATAD I and II rules;
Country-by-Country (CbC) Reporting; DAC 6 and DAC 7 mandatory
disclosure requirements; domestic top-up tax to ensure
a minimum level of taxation for multinational enterprise groups
and large-scale domestic groups.
Slovenia 22% No 5 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 No (no limitation There is a beneficial tax and a legal regime called DiiaCity for
period except for IT companies and start-ups.
large taxpayers)

Uzbekistan 15% No No No limits. Until January 1, 2028, VAT exemption is given to the turnover
on the sale of goods (services) as well as import of goods
purchased within the framework of projects implemented fully
or partially at the expense of the state external debt raised and
attracted from international financial institutions and foreign
governmental financial organizations by budgetary organizations,
as well as state enterprises and legal entities with the governments
share in the amount of 50%. This benefit also applies to project
participants.

Central and Eastern European tax guide 2025 Forvis Mazars 67