Page 68 - CEE Tax Guide 2025

Pillar 2 implementation

Was the Council Directive (EU) 2022/2523 implemented into the local legislation? Did the local legislation implement IIR? Did the local legislation implement UTPR? Did the local legislation implement QDMTT? What tax types qualify as covered taxes under the GloBE rules? Does the local law include any significant difference compared to the Directive?

Albania N/A New Law effective
from January 2024,
is partially aligned
to the Directive.

Austria CIT(Körperschaftsteuer) No
Bosnia and Herzegovina (FBiH) No No No No N/A N/A

Bosnia and Herzegovina (RS) No No No No N/A N/A
Bulgaria Tax on income No
of constituent entity,
on profit distribution,
retained earnings.
Croatia There is no significant No
distinction between
local law and
the Directive.
Czech Republic CIT including capital No
gain tax, windfall tax,
adjusted deferred tax.
Estonia No No No No N/A N/A

Germany Corporate and trade No, but the option
tax as well as the for the national
solidarity surcharge, supplementary
capital gains tax. tax was taken.
Greece The law does not specify No significant
which Greek taxes difference.
are included under
covered taxes.
Hungary CIT, local business tax, Calculation
innovation contribution, may be based on
Robin Hood tax. Hungarian
Accounting
Standards.

Kazakhstan No No No No N/A N/A
Kosovo No N/A N/A N/A N/A N/A

Kyrgyzstan No No No No N/A N/A

Central and Eastern European tax guide 2025 Forvis Mazars 68