Tax Surveys A European Comparison

Transcription

1 Tax Surveys A European Comparison 2014

2 A European Comparison of the following taxes for 2014 was undertaken Agenda 1. The Countries Involved 2. Salary Taxes, Social Security & Expat Tax 3. Self Employed Tax 4. Corporate Tax 5. Parent Company Tax 6. Gift & Inheritance Tax 7. Value Added Tax 8. Q&A 2

3 AGN Offices in the following Countries Completed the Survey: 22 of 28 European Union Countries: Austria, Belgium, Cyprus, Croatia, Czeck Republic, Denmark, Estonia, Finland, France, Germany Greece, Ireland, Italy, Luxembourg, Netherlands, Poland, Portugal, Romania, Slovakia, Spain, Sweden, United Kingdom. (Missing Bulgaria, Hungary, Latvia, Lithuania, Malta, Slovenia) 6 Non-European Union Countries: Isle of Man (except for VAT), Liechtenstein, Russia, Switzerland, Turkey, Ukraine. 2

4 SALARY TAX and SOCIAL SECURITY 2014

5 Salary Tax and Social Security 2014 Net Salary Income Tax Employees Social Security Employers Social Security

6 Salary and Social Security Tax Change 1 Russia 1 Russia 2 Liechtenstein 2 Liechtenstein 3 Isle of Man 3 Isle of Man 4 Estonia 4 Estonia 5 Romania 5 Romania 6 France 6 Switzerland Cyprus 7 France Slovakia 8 Cyprus Serbia 9 Czech Republic Luxembourg 10 Slovakia Czech Republic 11 Luxembourg - 1

7 Salary Tax and Social Security 2014 Net Salary: Russia leaves 88% net in the pocket of the individual, Liechtenstein 86% and Luxembourg 70% and Belgium the least 49%. Employers Cost: In Belgium the cost of employing someone is 280% of net salary, In Sweden 250%, in Austria and France 200% and in Luxembourg 161% 5

8 Salary Tax and Social Security 2014 Company Cars are taxed in all countries including Luxembourg, except Greece, Poland, Turkey and Russia, and the amount is generally based on vehicle catalogue price. Some use actual invoiced price, some, Isle of Man, use engine size and some use CO 2 emissions. The Netherlands charges less tax on environmentally friendly cars. Company Pension Schemes: premiums paid by employers are taxed as a benefit in only in Cyprus, Liechtenstein, and Luxembourg charges a 20% withholding tax. Other Insurance Premiums paid by employers for life, sickness, invalidity and surviving spouse benefits are not taxed as a benefit in about 50% of the countries and 100% in Luxembourg Lap-Top Computers and Internet costs are generally not treated as a benefit in kind. 6

9 Salary Tax and Social Security 2014 Expatriate Schemes: Belgium, France, Romania, Poland, Spain and United Kingdom do not tax employer funded home visit travel nor do they tax the payment of relocation costs. Only Cyprus (20%) the Netherlands and Luxembourg (30%) exempt from tax a percentage of the expatriate s income. Buying Property: Only Croatia, Poland and Liechtenstein do not allow expatriates to buy houses there. 7

10 SELF- EMPLOYED TAXATION 2014

11 Self Employed Taxation 2014 Net Income Income Tax Employee Social Security. Employer Social Security 9

12 Self Employed Tax Comparision Range 1 Russia 1 Russia 2 Czech Republic 2 Isle of Man Isle of Man 3 Czech Republic Romania 4 Liechtenstein Liechtenstein 5 Cyprus Poland 6 Switzerland Estonia 7 United Kingdom Cyprus 8 France Turkey 9 Luxembourg United Kingdom 10 Estonia France 11 Slovakia Luxembourg 12 Turkey

13 Self Employed Taxation 2014 Net Income: The least net income is left by: Belgium 36%, Germany 38% and Portugal 45%. The best net income is left by: Russia 92%, Isle of Man 81% and Czech Republic 82%. In Luxembourg a self employed person is left with 62% of his gross income Social Security Contributions: are a deductible expense except the Czech Republic, Ireland, Isle of Man and the UK VAT Registration: is required with a registration threshold for majority of the countries except in Russia. Depreciation: is allowed as a tax deduction except in the UK (the UK has a capital allowances system). 10

14 Self Employed Taxation 2014 Mortgage Payments: are allowed as a deduction in all except Austria, Cyprus, Germany, Ireland, Liechtenstein, Russia, Slovakia, Sweden, Turkey and the UK. Travel Expenses are allowed as a deduction except in Russia. Entertaining Expenses are not allowable in Czech Republic, Greece, Ireland, Poland, Portugal, Russia, Slovakia, Turkey and the UK. Flat Rate Deductions are allowable in only 9 countries surveyed Austria, Czech Republic, Estonia, Germany, Liechtenstein, Netherlands, Portugal, Slovakia, and Spain. 11

15 Self Employed Taxation 2014 Deductions in respect of the Taxpayer s Children are not allowed in Cyprus, Denmark, Greece, Isle of Man, Ireland, Netherlands, Poland, Russia, Sweden, Turkey and the UK. Non-Working Spouse: A deduction in respect of the taxpayer s non working spouse is not allowed in Cyprus, Denmark Germany, Greece, Netherlands, Poland, Russia, Spain, Sweden, Switzerland, Turkey, and the UK. The most generous jurisdiction is the Isle of Man where 11,453 is allowed. 11

16 CORPORATE TAX 2014

17 Corporate Tax 2014 Net Dividend Corporate Tax Withholding Tax

18 Corporate Tax Comparision Change 1 Isle of Man 1 Isle of Man 2 Malta 2 Cyprus Cyprus 3 Hungary Hungary 4 Liechtenstein Liechtenstein 5 Slovakia Slovakia 6 Luxembourg Serbia 7 United Kingdom Luxembourg 8 Croatia

19 Corporate Tax: Nominal corporate tax rates These range from: 0% IM (except for rental profits from Manx property, and local banking services) 10% to 12.5% Hungary, Cyprus, Ireland and Liechtenstein 16% Romania 19% Poland and Czech Republic 21% Luxembourg (x unemployment surcharge + municipal tax so 29.22% in reality) 26% Greece and Spain 33-35% Belgium, France, Malta, Germany, Italy, Norway, Sweden Turkey and the UK 19

20 Corporate Tax 2014 Nominal Tax Rates vs Effective Tax Rates: The truth however lies in comparing the effective corporate tax burden, thus considering taxable adjustments of the accounting profit and withholding taxes on business expenses such as intercompany interest and royalties. Effective corporate tax rates range from approximately 13% in Cyprus and Luxembourg, to 47% in France. However, most countries surveyed have an effective corporate tax rate between 23% and 38%. Poland shows the largest divergence between the nominal at 19% and effective 40% rates. 20

21 Corporate tax 2014 Net dividends received by shareholders The range of accounting profit distributed to shareholders is: Individual shareholder resident in same country: From 84% Liechtenstein to 35% France. Luxembourg 74% Individual shareholder resident in treaty country: From 87% Cyprus to 42% France. Luxembourg 79% Individual shareholder resident in non-treaty country: From 87% Cyprus to 13% France. Luxembourg 74% EU resident company as shareholder: From 87% Cyprus, Luxemburg to 53% France. Luxembourg 88% Treaty country (non EU) resident company as shareholder: From 87% Cyprus, Luxemburg to 45% France. Luxembourg 88% Non-treaty country resident company as shareholder: From 87% Cyprus to 42% France. Luxembourg 74% 21

22 Corporate Tax 2014 Tax adjustments to the accounting profit: Most countries adjust accounting profit (usually increases) to arrive at taxable profit. Complimentary pension provisions: The Czech Republic, France, Ireland, Poland, Romania, Spain, Turkey and the UK do not allow deduction of company pension provisions. Luxembourg does but there is a 20% withholding at source. Non-executive directors fees: Austria and Germany allow a 50% deduction. Ireland, Poland, Spain, allow a deduction, but charge a withholding tax. Czech Republic, Greece, Luxembourg and Russia disallow them completely and charge a withholding tax (Luxembourg 20%). Depreciation: is not deductible in Czech Republic, Hungary, Ireland, Isle of Man, Russia and the UK. UK allows capital allowances. 22

23 Corporate Tax 2014: Adjust Commercial Result Company cars: Austria, Croatia, France, Ireland, Liechtenstein, Poland, and Portugal set a maximum purchase price. Annual depreciation rates range from 12,5% Austria to 50% Turkey. Luxembourg No limit depreciation 4 years Intercompany interest deduction: Most countries apply the arm s length principle for interest intergroup loans and about 50% apply thin capitalization rules. Belgium, Croatia, the Czech Republic, Greece, Romania, Russia, and the UK apply withholding taxes between 5% and 25% on intercompany interest payments. Luxembourg sets acceptable margins Royalties: Denmark, Hungary, Isle of Man, Liechtenstein, Luxembourg, the Netherlands, Switzerland and Sweden do not apply withholding taxes to royalties paid to EU companies. The others do at rates between 10% Poland, France and Cyprus and 25% Belgium. 23

24 PARENT COMPANIES 2014

25 PARENT COMPANIES 2014 Net Cash Received Corporate Tax Withholding Tax on Dividend Withholding Tax on Interest

26 Parent Companies Tax Comparision Range 1 Switzerland 1 Isle of Man Liechtenstein 2 Switzerland Cyprus 3 Liechtenstein Malta 4 Cyprus Sweden 5 Sweden 6 Denmark 6 Denmark 7 Norway 7 United Kingdom United Kingdom 8 Luxembourg Luxembourg 9 Netherlands - 1

27 Parent Companies 2014 Net cash receivable by paid to a non-eu tax haven parent company: The Isle of Man distributes 100% of the profit made by the parent company, Switzerland 99%, Liechtenstein 96% and Cyprus 95% and Luxembourg 84%. Bottom of the list comes Portugal 52%, the Czech Republic 62% and Greece 64%. Dividend income: 100% exemption by most countries including Luxembourg except 95% in Belgium, France, Germany and Italy. 0% in Russia and Turkey. Dividend withholding tax credits: If dividends are taxed then a tax credit for the withholding tax on dividend income from a USA participation is granted in Italy, Poland and Russia and from a Swiss, French and German participation in Italy and Russia. 26

28 Parent Companies 2014 Capital gain on sale of subsidiaries: 100% in most countries including Luxembourg. 95% is exempt in Germany and Italy 88% is exempt in France. Fully taxed in Greece, Poland, Slovakia, Turkey and Ukraine Investment costs write down of subsidiaries: 100% allowed in Austria, Isle of Man, Luxembourg, Slovakia and Switzerland. Interest deduction to finance purchase of subsidiary: 100% deductible in most countries including Luxembourg except Cyprus, the Czech Republic, Italy and Turkey. 27

29 Parent Companies 2014 Interest withholding tax paid to a non-eu tax haven parent company: No withholding tax in Austria, Cyprus, Denmark, France, Germany, Ireland, Isle of Man, Liechtenstein, Luxembourg, the Netherlands, Poland, Portugal, Sweden and Switzerland The rate in the rest varies between 15% and 25%, Belgium being on the higher end. Dividend withholding tax on dividends paid to a non-eu tax haven parent company: No withholding tax in Cyprus, Denmark, Isle of Man, Liechtenstein, Slovakia, Sweden, Switzerland, and the UK. In other countries the rate varies from 10% to 35%. Luxembourg is 15% 28

30 GIFT & INHERITANCE TAX 2014

31 GIFT & INHERITANCE TAX 2014 Proportion of estate retained Effective Tax payable

32 Gift & Inheritance Tax Comparision Change 1 Austria 1 Austria 2 Croatia 2 Croatia 3 Cyprus 3 Cyprus 4 Czech Republic 4 Czech Republic 5 Estonia 5 Estonia 6 Italy 6 Isle of Man Liechtenstein 7 Italy Luxembourg 8 Liechtenstein Poland 9 Luxembourg

33 GIFT & INHERITANCE TAX 2014 Tax Rate: In almost all the jurisdictions surveyed the tax rate is based upon the total value of the assets and the relationship of the heirs to the deceased. It can also vary according to the type of the asset. Only Denmark has a fixed tax rate. Beneficiaries: In France and Luxembourg, there are forced heirship rules which dictate the portion of the estate that the children must receive. In other countries that is freely determinable. Exemption for assets transferred to the spouse is not granted in Belgium, Germany, Greece, Italy, the Netherlands, Spain, and Turkey. In Luxembourg only to a spouse with surviving children Exemption for assets transferred to children is granted in Croatia, Czech Republic, 14 Luxembourg, Poland, Portugal, and Switzerland

34 GIFT & INHERITANCE TAX 2014 Valuation of Assets: Family Home: Usually at current market value except France and Spain (5% of MV, but limited to per individual). Share Portfolio: must separate quoted shares and unquoted shares or family businesses. Ireland (10%), Spain (5%) and the United Kingdom (0%) apply reduced rates to unquoted family business shares. All countries surveyed include quoted shares at 100% of the market value. Cash: included at 100% of its value. 15

35 V.A.T 2014

36 V.A.T Rates 2014

37 European VAT 2014 Comparision Change 1 Luxembourg 1 Switzerland Turkey 2 Liechtenstein Serbia 3 Luxembourg Russia 4 Turkey Malta 5 Russia Cyprus 6 Germany Germany 7 Cyprus France 8 United Kingdom United Kingdom 9 Ukraine

38 V.A.T Rates V.A.T Rates: vary from 8% in Liechtenstein and Switzerland, 15% in Luxembourg and up to 25% in Croatia, Denmark and Sweden. The most common rate is 20% in Austria, Estonia, France, Isle of Man, Ukraine and United Kingdom. V.A.T Registration: There is no turnover limit to exceed in Italy, Netherlands Portugal Spain, Sweden and Turkey. The highest threshold is Russia with 170k and Isle of Man and UK at 95k, France, Liechtenstein and Switzerland at 82k, Ireland 72k, and Romania at 65k. Luxembourg is 25k. Only Spain does not allow voluntary registration 31

39 V.A.T Rates Distance Selling Threshholds: There are no turnover thresholds in Russia and Turkey and the others vary from 25k in Ukraine and 100k in France, Germany, Isle of Man, Italy, Luxembourg, Netherlands and UK. The rest have a threshold of between 32k and 37k except Liechtenstein and Switzerland that are at 82k V.A.T. Invoice: Only in Ireland Liechtenstein and Switzerland do you not need to mention on the invoice why you have not charged VAT. Reclaim of V.A.T. in another country: Only not possible in Ukraine and Russia. You need a VAT representative in Liechtenstein, Switzerland, Portugal, Romania, Spain Turkey,and Ukraine and you do not need to submit original invoices in Czeck Republic, Finland, Isle of Man and Sweden. You do not need to prove your VAT 32 registration in your own country to Czech Republic and Croatia

40 Q&A Thank you for listening If you want to go into more detail on the surveys and download them please go to and on the right click on tax surveys. There you find the ressults of these surveys since Or call us to discuss All the firms that have provided tax information are listed in the following link: TAX SURVEYS / AGN EUROPE TAX EXPERTISE or click on the following link: 33