Page 7 - CEE Tax Guide 2025
P. 7
country reporting”), which promotes transparency
by providing local tax authorities with the
information necessary for evaluating tax risks. There
is mandatory TP documentation obligation in all
countries, except Kyrgyzstan.
Pillar II (GloBE Minimum Tax)
A key focus in international taxation is currently the
introduction of global minimum taxation, based
on the so-called Pillar II framework of the G20/
OECD. On the basis of EU Directive 2022/2523
EU countries must implement the EU Directive into
their domestic legislation. Based on the responses
received, this has already happened in fourteen
countries: Albania, Austria, Bulgaria, Croatia,
the Czech Republic, Germany, Greece, Hungary,
Lithuania, North Macedonia, Poland, Romania,
Slovakia, and Slovenia.
A set of complicated and interlocked rules were put
in place to ensure minimum effective taxation for
corporate groups with an annual revenue of at least
EUR 750 million. Based on these rules, a “qualifying
domestic top-up tax” should be collected if the
effective tax rate in a given jurisdiction is below
15%. It is clear that there are increasingly fewer
opportunities for multinational companies to engage
in profit-shifting.
Central and Eastern European tax guide 2025 Forvis Mazars 7
