Hong Kong Last reviewed: 18 March 2014 A. Companies 1. Resident companies Corporate tax rates 16.5%

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Clemence Lamb
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1 Hong Kong Last reviewed: 18 March 2014 A. Companies 1. Resident companies Corporate tax rates 16.5% Tax base territorial Unilateral double taxation relief 2. Non- Corporate tax rates 16.5% on sale of shares in Branch profits Dividends Interest 4.95% (30% of profits x corporate tax rate) Fees (management) 3. Specific issues Participation relief n/a (all dividends are exempt from taxation) Group treatment Incentives high value manufacturing; qualifying debt instruments; qualifying reinsurance business; offshore mutual funds Anti-avoidance general rule; transfer pricing B. Individuals 1. Resident individuals Unilateral double taxation relief 2. Non-resident individuals on sale of shares in top rate 17% (income over HKD 120,000); standard tax rate 15%; unincorporated business income 15% (profits tax) top rate 17% (income over HKD 120,000) IBFD

Specific issues Participation relief n/a (all dividends are exempt from taxation) Group treatment Incentives high value manufacturing; qualifying debt instruments; qualifying reinsurance business;

2 Hong Kong Employment income Dividends Interest Fees (directors) C. Other direct taxes Net wealth tax Inheritance and gift taxes D. Turver taxes VAT/GST (standard) VAT/GST (reduced) VAT/GST (increased) Other salaries tax is levied on a provisional basis 4.95% (30% of profits x corporate tax rate) 2014 IBFD 198

Turver taxes VAT/GST (standard) VAT/GST (reduced) VAT/GST (increased) Other

3 Hungary Last reviewed: 1 May 2014 A. Companies 1. Resident companies Corporate tax rates Tax base Unilateral double taxation relief 2. Non- Corporate tax rates on sale of shares in 10% up to HUF 500 million; 19% over HUF 500 million worldwide part of business income; participation exemption for reported participation (at least 10% of capital, reported to tax authority, maintained for at least 1 year); gains on disposal of certain intangible assets exempt, ordinary foreign tax credit for maximum 90% of the foreign tax 10% up to HUF 500 million; 19% over HUF 500 million t taxable generally, however, 19% upon transfer of shares in real estate holding company Branch profits Dividends 0% Interest 0% 0% 0% Fees (management) 0% 3. Specific issues Participation relief inbound dividends: exempt outbound dividends: exempt Group treatment Incentives investment (with specific purpose); promotion of development; employment; SMEs; film production; sport subsidies; REITs regime; R&D IBFD

of capital, reported to tax authority, maintained for at least 1 year); gains on disposal of certain intangible assets exempt, ordinary foreign tax credit for maximum 90% of the foreign tax 10% up to

4 Hungary Anti-avoidance general rule; transfer pricing; thin capitalization; CFC (in relation to n-treaty countries and n-oecd/eu Member States) B. Individuals 1. Resident individuals 16% part of rmal income; 25% under certain circumstances Unilateral double taxation relief, ordinary foreign tax credit for maximum 90% of the foreign tax paid on foreign-source active income 2. Non-resident individuals 16% on sale of shares in t taxable generally, however, 16% tax on capital gains realized upon transferring interests in qualifying real estate holding companies Employment income general wage withholding applies Dividends 16% Interest 16%; 10% (held at least 3 years ); 0% (EU resident or held at least 5 years) (progressive, assessment) (progressive, assessment) Fees (directors) (progressive, assessment) C. Other direct taxes Net wealth tax Inheritance and gift taxes D. Turver taxes VAT/GST (standard) 27% VAT/GST (reduced) 0%, 5%, 18% VAT/GST (increased) Other local business tax, simplified entrepreneurial tax 2014 IBFD 200

5 Iceland Last reviewed: 1 May 2014 A. Companies 1. Resident companies Corporate tax rates 20%; 36% for partnerships registered as legal entities Tax base worldwide part of business income; gains on shares are exempt Unilateral double taxation relief, ordinary foreign tax credit 2. Non- Corporate tax rates 20% on sale of shares in 20% Branch profits Dividends 18% Interest 10%; 0% on certain bonds; if exempt in recipient s resident state; if paid by the Central Bank 20% 20% Fees (management) 20% 3. Specific issues Participation relief inbound dividends: outbound dividends: Group treatment Incentives tax concessions for direct investment Anti-avoidance transfer pricing; CFC regime B. Individuals 1. Resident individuals Unilateral double taxation relief national income: top rate 31.8% (over ISK 9,415,428); employment income: top rate 46.24% (over ISK 784,619); municipal income tax: average rate 14.4% part of business/investment income; privately owned movable/immovable property is exempt, ordinary foreign tax credit IBFD

6 Iceland 2. Non-resident individuals national income tax: top rate 31.8% (over ISK 9,415,428); employment income: 18% (assessment); municipal income tax - average rate 14.4% flat rate of 20% (assessment) on sale of shares in Employment income 18% (by assessment) Dividends 20% Interest 10%; 0% on interest income up to ISK 125,000 20% 18% Fees (directors) 18% C. Other direct taxes Net wealth tax Inheritance and gift taxes D. Turver taxes VAT/GST (standard) 25.5% VAT/GST (reduced) 0%, 7% VAT/GST (increased) Other, inheritance tax (gifts are taxed according to the rmal tax schedule) 2014 IBFD 202

4% flat rate of 20% (assessment) on sale of shares in Employment income 18% (by assessment) Dividends 20% Interest 10%; 0% on interest income up to

7 India Last reviewed: 1 January 2014 A. Companies 1. Resident companies Corporate tax rates 30%; surcharge (SC) of 5% where total income exceeds INR 10 million and 10% where total income exceeds INR 100 million; 2% education cess (EC) and 1% secondary and higher education cess (SHEC) also levied on income tax payable (including surcharge where applicable); effective tax rate including above surcharge and cesses is % (with 5% SC) or 33.99% (with 10% SC) Tax base worldwide part of business income or specific regime depending on nature of taxpayer s business Unilateral double taxation relief 2. Non- Corporate tax rates 40%; surcharge (SC) of 2% where total income exceeds INR 10 million, and 5% where total income exceeds INR 100 million; 2% education cess (EC) and 1% secondary and higher education cess (SHEC) also levied on income tax payable (including surcharge where applicable); effective tax rate including above surcharge and cesses is % (with 2% SC) or 43.26% (with 5% SC) on sale of shares in Branch profits Dividends (a final dividend distribution tax is payable by the dividend-paying company at 15% plus 10% SC, EC and SHEC, i.e. an effective rate of %) Interest 20% (21.012% including SC, EC and SHEC for income between INR 10 million and INR 100 million, or 21.63% for income exceeding INR 100 million) IBFD

and higher education cess (SHEC) also levied on income tax payable (including surcharge where applicable); effective tax rate including above surcharge and cesses is 32.445% (with 5% SC) or 33.

8 India Fees (management) 3. Specific issues Participation relief Group treatment Incentives Anti-avoidance B. Individuals 1. Resident individuals Unilateral double taxation relief 25% (26.265% including SC, EC and SHEC for income between INR 10 million and INR 100 million, or % for income exceeding INR 100 million) 25% (26.265% including SC, EC and SHEC for income between INR 10 million and INR 100 million, or % for income exceeding INR 100 million) 25% (26.265% including SC, EC and SHEC for income between INR 10 million and INR 100 million, or % for income exceeding INR 100 million) inbound dividends: outbound dividends: research companies; mineral oil production; cold chain facilities; shipping and air transportation; hotels; hospitals; power sector; manufacturing sector specific rules dealing with the holding period of income securities; transfer of income and immovable property; transfer pricing top rate 30% (on income over INR 1 million); 2% education cess (EC) and 1% secondary and higher education cess (SHEC) also levied on income tax payable; additional surcharge of 10% applicable on tax payable where total income exceeds INR 10 million, resulting in effective top rate of 33.99% specific regime 2014 IBFD 204

265% including SC, EC and SHEC for income between INR 10 million and INR 100 million, or 27.

9 2. Non-resident individuals India schedular; top rate 30% (on income over INR 1 million); 2% EC and 1% SHEC also levied on income tax payable; additional surcharge of 10% applicable on tax payable where total income exceeds INR 10 million, resulting in effective top rate of 33.99% on sale of shares in Employment income top rate 30% (on income over INR 1 million); additional surcharge of 10% applicable on tax payable where total income exceeds INR 10 million, resulting in effective top rate of 33.99% Dividends Interest Fees (directors) C. Other direct taxes Net wealth tax Inheritance and gift taxes D. Turver taxes VAT/GST (standard) VAT/GST (reduced) VAT/GST (increased) Other (a final dividend distribution tax is payable by the dividend-paying company at 15% plus 10% SC, EC and SHEC, i.e. an effective rate of %) 10%/20% (11.33% / 22.66% including SC, EC and SHEC) 25% (28.325% including SC, EC and SHEC) 25% (28.325% including SC, EC and SHEC) 25% (28.325% including SC, EC and SHEC) (exists at state level) (exists at state level) (exists at state level) central sales tax on interstate sale of goods at 2% or 10%, or the prevailing state value added tax or state sales tax rate, whichever is higher; service tax at 12% (12.36% including EC and SHEC) on specified services; commodities transaction tax at 0.01% on commodities transactions IBFD

99% on sale of shares in Employment income top rate 30% (on income over INR 1 million); additional surcharge of 10% applicable on tax payable 99% Dividends Interest Fees (directors) C.

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