Germany taxes its corporate residents on their worldwide income. However, most double tax treaties (DTTs) exempt income attributable to a foreign permanent establishment (PE). Non-residents with PE or property income are taxed by assessment on German-source income; those earning royalties and dividends
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A resident company is subject to corporate income tax (CIT) in France on its French-source income. In that respect, income attributable to foreign business activity (if there is no treaty in force between France and the relevant foreign country) or to a foreign
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All undistributed corporate profits are tax exempt. This exemption covers both active (e.g. trading) and passive (e.g. dividends, interest, royalties) types of income. It also covers capital gains from the sale of all types of assets, including shares, securities, and immovable property.
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Corporate income tax (CIT) In general, the tax base for CIT purposes is determined on an accrual basis and consists of worldwide income less allowed deductions. The rules are equally applicable to companies and PEs. It is assumed that all income received
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Basis of corporate income tax (Körperschaftsteuer) Corporations (i.e. limited liability corporation [GmbH], stock corporation [AG]) are subject to unlimited taxation in Austria of their entire (domestic and foreign) income if they have their legal seat or place of effective management in Austria.
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Luxembourg taxes its corporate residents on their worldwide income and non-residents only on Luxembourg-source income. Businesses with taxable income lower than 175,000 euros (EUR) are subject to corporate income tax (CIT) at a rate of 15%. Businesses with taxable income between EUR 175,000
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As a business owner, the ambition to set up multiple branches worldwide represents not just your success but also a strategic move towards expansive growth and diversification. If your business is evolving beyond your local boundaries, you may be ready to embrace
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Expanding your business across international borders is an ambitious yet rewarding venture. However, it’s a path that may not suit every business at any given time. The decision to expand globally goes beyond the typical metrics of financial health and market growth.
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HMRC issues its guidelines for compliance on what qualifies as R&D for tax purposes. The publication of HMRC’s latest guideline highlights the importance of correctly identifying whether a research and development (R&D) claim meets the necessary conditions to qualify for tax relief.
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Individual – Foreign tax relief and tax treaties Last updated – 08 January 2024 Foreign tax relief Foreign income received by residents that is subject to a tax equivalent to Luxembourg income tax and is not exempted by a DTT is granted
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