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["Countries ","What foreign entities qualify? ","Below what rate?","What income is taxed? "]
["Argentina","De minimis:  only passive income is taxed if not (1) at least 50% of the earnings of the foreign entity is passive income orJurisdiction: list of (1) non-cooperative jurisdictions including all jurisdictions that do not have an information exchange or convention for the avoidance of double taxation including an information exchange clause in place with Argentina, and (2) jurisdictions with information exchange agreements in place but not complying and (3) every jurisdiction, country, domain, associated state, territory or special tax regime with a maximum corporate income tax rate below 60% of the Argentine CIT rate.  Control: (1) Argentine resident has voting or economic rights of 50% or more. (Any interest held indirectly or directly by family members will be added for purposes of calculating the 50% or (2)  has the right, in any way, to dispose or decide on the disposal assets of the legal entity, has the right to appoint the majority of the directors, administrators or deciding members of the administration boards or bodies, and has the right to remove the majority of the directors or administrators, and has a current right on the benefits of the legal entity, IF, at any moment during the financial year, the foreign entity has financial assets that produce Argentine-source passive income that is exempt from Argentine income tax and represents 30% or more of it total assets substance carve- out:  (1) the foreign entity does not have the necessary material and personal means to perform its activity or (2) its income causes direct or indirect deductions to an Argentine tax resident related party","ETR is 75% or lower than the tax that would be applicable in accordance with the Argentine corporate taxation regime. This requirement is deemed to be met – with no possibility of proving to the contrary – if the foreign entity is incorporated, domiciled or placed in a non-cooperative jurisdiction as defined by special list (see Jurisdiction, category B)","Whole of CFC income if no substance, if substance then only passive income (see substance carve--out under category B)"]
["Australia","Jurisdiktion: Whitelist affects what income is taxed. De minimis: active income test affects what income is taxed Control: if five or fewer residents have 50% associate-inclusive control, or a single resident has 40% associate-inclusive control, or a group of five or fewer residents has actual control, of the company. An attributable taxpayer must have at least 10% associate-inclusive control (or 1% if the taxpayer is one of the five or fewer residents controlling the CFC).","None ","If the CFC passes the active income test, there is no attribution of income other than specified income, which is attributed unconditionally (e.g. notional FIF (see below) income of the CFC). If the CFC fails the active income test, only specified concessionally taxed income will be attributed if the CFC is a resident in a whitelisted country; if the CFC is a resident in an unlisted country, “tainted” income of the CFC is attributed (which is, generally, income from dealing with Australian residents and passive income)."]
["Austria ","De minimis: Passiv inkomst must exceed a third of total income- all or nothing. Jurisdiction: Control: directly or indirectly, with its affiliated companies, more than 50% of the voting rights or capital or is entitled to more than 50% of the profits of the foreign corporation. significant economic activity: worldwide","ETR half of what would apply in Austria","passive income "]
["Azerbadjan","De minimis: Jurisdiction: Low tax according to black list made by president. Control: directly or indirectly more than 20% of share capital or voting rights in a foreign legal entity","None ","Whole of CFC income"]
["Belgium","De minimis: Jurisdiktion: Controll: Corporation, accosiatives- inclusive, holds directly or indirectly: (i) the majority of the voting rights, (ii) at least 50% of the participation or (iii) the right of the majority of the profits of the foreign entity. “non-genuine arrangements”: worldwide","ETR 1/2 or lower than what would have been applied in Belgium. ","Not proportional approach, instead income is  taxed to the extent it is connected to assets and risks. No deduction at all for taxes allready paid on income. "]
["Brazil","Brazil has four different sorts. Regular Controlled, Regular associated, legally differentiated controlled and legally differenciated associated. Associated companies are legally differentiated if they: (1) are located in a blacklisted jurisdiction or (2) ETR is lower than 20% or (3) are controlled, directly or indirectly, by a legal entity subject to ETR below 20%. Controlled companies are also legally differentiated if they: (1) meet one of above listed criteria or (2) are located in a jurisdiction with which Brazil does not maintain a treaty or an act with a specific clause for the exchange of information for tax purposes; (3) are controlled, directly or indirectly, by a legal entity located in a blacklisted jurisdiction or (4) active income is less than 80% of the total income. De minimis: see above Jurisdiktion: see above Control: controlled: holds, directly or via related (read broadly) parties, rights that assure, on a permanent basis, the power to elect the majority of the directors and to prevail in corporate decisions. Associated: significant influence, considered as power to take part in the definition of the company’s financial and operating policy, without having control of the company. Significant influence is presumed when the investor owns 20% or more of the shares of the company ","see column B.","Whole of CFC income (for regular associated companies through deemed-dividend) (for legally differentiated controlled companies, offsetting profits of one foreign company against losses of the other foreign company is not allowed.)."]
["Bulgarien","De minimis: Jurisdiktion: Controll: alone or together with its related parties, holds directly or indirectly more than 50% of the voting rights, capital or share in profits of the non-resident entity substantive economic: worldwide","ETR 1/2 than the tax that would have been paid by that entity in Bulgaria, 4,99% (exception when no tax what so ever is payed!)","Whole of CFC income"]
["Cabo Verde","De minimis: Jurisdiction: Control: holds, directly or indirectly, even if through a legal representative (mandatário), a fiduciary (fiduciário) or an intermediary (interposta pessoa), 25% of the share capital, voting rights, rights to income or rights to the assets of the CFC entity","None ","Whole of CFC income"]
["Canada","De minimis: Jurisdiction: Control: In general, a foreign corporation is a foreign affiliate of a Canadian corporation if: (1) the Canadian corporation owns, directly or indirectly, at least 1% of any class of the outstanding shares of the foreign corporation, and (2) the Canadian corporation, alone or together with related persons, owns, directly or indirectly, at least 10% of any class of the outstanding shares of that foreign corporation.\nThe foreign affiliate will be a controlled foreign affiliate of the Canadian corporation if certain conditions are met (e.g. more than 50% of the voting shares are owned, directly or indirectly, by a combination of the Canadian corporation, persons at non-arm’s length with the Canadian corporation, a limited number of Canadian-resident shareholders, and persons at non-arm’s length with those Canadian-resident shareholders).","None ","the resident’s share of any foreign accrual property income (FAPI) = foreign direct investment income of a passive nature (such as dividends, interest, rent and royalties), certain capital gains, income from an investment business (unless the business employs at least six full-time employees) and certain other income. In sum: mainly categories of passive income and limited active"]
["Chile","De minimis: the total foreign income received or accrued by the CFC in a given taxable period must exceed 2,400 UF (USD 92,735). Profits must consist of 10% passive income. The value of the assets of the foreign controlled entity that may generate passive income must exceed 20% of the total value of its assets. Passive income must be 30% in the country of domicile, the country of incorporation or where the entity is established. Jurisdiktion: Controll: directly or indirectly controlled by entities, (1) controlling more than 50% of the foreign entity’s capital, profits or voting power or (2) having power to elect the majority of directors or administrators of the foreign entity or (3) having the unilateral power to amend the foreign entity’s by-laws, or to change the majority of its directors or administrators","none","Passive income and limited active from transactions w/ chilean taxpayers. If the passive income is more than 80% of its total profits, 100% profits are deemed to be passive income."]
["China","De minimis: Total profit must exceed RMB 5 million. Exception if mainly obtains the income from active business activities. Jurisdiktion: White list Controll: directly or indirectly holding more than 10% of the voting shares of a foreign enterprise and jointly holding more than 50% of the shares of the foreign enterprise; or the resident enterprise and the Chinese individual resident who have no shareholding ratio but meet the above-mentioned standards in terms of shares, funds, operations, purchases and sales shall constitute substantial control over foreign companies. Substance carve-out: On undeclared profits kept without reasonable business reasons "," ETR 50% lower than the Chinese rate.","Passive "]
["Colombia ","De minimis: Jurisdiction: blacklist for financial institutions Control: one or more Colombian residents holds 50% of vote, value, or the right to receive profits. Only shareholders who hold at least 10 percent of the voting shares, or a 10 percent right over the profits, has to include the corresponding share of income of the CFC. ","none ","Passive. "]
["Croatia (Kroatien)","De minimis: Jurisdiktion: Controll: the taxpayer by itself, or together with its related parties holds a direct or indirect participation of more than 50% of the voting rights, or owns directly or indirectly more than 50% of capital or is entitled to more than 50% of the profits of the foreign company substantive economic prescence: worldwide","actual tax paid is lower than 50% of the corporate income tax that would apply for such profits under the CIT applicable to the taxpayer.","passive income and limited active income from transactions between related parties. "]
["Cyprus","De minimis: its accounting profits must exceed EUR 750,000 and its non-trading income EUR 75,000. its accounting profits must exceed 10% of its operating costs for the tax period. Jurisdiktion: Controll: the taxpayer, either alone or jointly with its associated enterprises, holds directly or indirectly more than 50% of the voting rights in the CFC, or 50% of the capital, or is entitled to receive more than 50% of the CFC’s profits substantive economic prescence: worldwide","none ","passive. only the amount of non-distributed income of the CFC resulting from non-genuine arrangements."]
["Czech Republic","De minimis: Jurisdiction: Control: Czech controlling company holds directly or indirectly more than 50% of capital or voting rights by itself or together with associated persons; or is entitled to more than 50% of the profits.","ETR of the CFC in its country of residence is lower than half of the ETR a CFC would pay as a Czech tax resident","passive."]
["Danmark","De minimis: 50% of income must be tainted (passive + limited active from financial sector) and more than 10% of its assets must be of a financial nature. Jurisdiction: Control: “Deciding influence” - understood as the right to control the economic and operational decisions of the subsidiary. Deciding influence is presumed when a resident company with accosiates holds more than 50% of the voting power. Associates includes companies in agreement on constructive ownership. In addition, voting rights held by certain transparent entities in which the parent company is a participant should be included. ","none ","Whole of CFC income"]
["Egypt ","De minimis: 70% of the CFC income consists of passive income Jurisdiction: Control: the participation in the CFC’s share capital exceeds 10%","CIT does not exceed 75% of the tax rate applied in Egypt","Whole of CFC income"]
["Estonia","De minimis:  Jurisdiction: Controll: resident company alone or together with affiliated companies holds more than 50% of the shares, profits or voting rights of the CFC, or the CFC is a permanent establishment.","none ","All income when (1) the underlying transaction or chain of transactions of the CFC which created the profit was fictitious and (2) the principal aim of the underlying transaction or chain of transactions was to gain a tax advantage; (3) and the factual management of the CFC is carried out by key employees of the shareholder (the controlling company)."]
["Finland","De minimis:  Jurisdiction: C/ in White list excluded Control: the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of at least 25% of the voting rights, or owns directly or indirectly at least 25% of capital or is entitled to receive at least 25% of the profits of the entity or of the yield of the entity's assets Substantive economic activity: EEA","ETR in residence country is less than three fifths of the Finnish corporate income tax rate, currently 12% (60% of the Finnish tax rate of 20%)","Whole of CFC income"]
["France","De minimis:  Jurisdiktion:  CIT rate lower than 50% of french Controll: directly or indirectly hold a participation of more than 50% in a non-resident entity or permanent establishment or 5% when more than 50% of the shares in the non-resident company are owned by French companies or by non-resident companies directly or indirectly controlled by a French company.","effective taxation is at least 60% lower than that of France ","income derived from permanent establishments is taxed as business profits. Income derived from companies is taxed as passive income under a “deemed dividend” approach, in the proportion of stock, shares or financial rights held directly or indirectly by the French entity."]
["Germany ","De minimis: (1) the passive income must amount to more than 10% of the total gross income of the foreign company and (2) the amounts to be disregarded must exceed EUR 80,000 both for the company and for the taxpayer. Jurisdiction: Control: more than 50% of the non-resident company’s capital or voting power is owned by resident companies and/or resident individuals (irrespective of their relationship to each other), directly or indirectly. The control threshold is lowered to 1% or even completely waived for certain types of capital income - investment income. substantive economic activity: EEA","ETR below 25%","passive, defined negatively by way of catalogue on \"harmless income\". (hybrid of deemed dividend/ piercing the veil)"]
["Greece ","De minimis: over 30% of the net income before taxes of the CFC must be passive income Jurisdiction: Control: the  taxpayer (with or without any related parties) directly or indirectly holds at least 50% of the shares, participation, voting or capital rights in the CFC, or is entitled to receive at least 50% of the CFC's profits;","the actual corporate tax paid by the CFC is lower than the difference between the tax that it would pay in Greece and the amount paid by the CFC","Whole of CFC income"]
["Hungary ","De minimis: (1) pre tax profit must exceed HUF 243,952,500 and the “income derived from non-commercial activities” must exceed HUF 23,495,250 and (2) must represent more than 10% of its operating costs for the tax year. Jurisdiction: Control: the taxpayer, either on its own or together with related entities/persons (1) holds a direct or indirect participation of more than 50% of the voting rights or registered capital or is entitled to more than 50% of profits, if (2) the participation or entitlement  persists during the majority of the tax year. The threshold for being related persons for CFC purposes is 25% participation, voting right or right to profit distributions. Substantive economic prescence: worldwide","the actual corporate tax paid by the CFC is lower than the difference between the tax that it would pay in Hungary and the amount paid by the CFC","limited passive (to the extent of amounts generated through assets and risks, which are linked to significant people functions carried out by the controlling Hungarian tax resident entity)"]
["Iceland ","De minimis: the income must be more than 50% financial income if resident in treaty state. Jurisdiction: Control: owned or controlled, directly or indirectly, for at least 50% by resident taxpayers (corporate or individual) substance carve-out: EEA/EU when exchange of information exists. ","the general income tax rate on corporate profits is less than two thirds of the Icelandic rate which would apply if the company were resident in Iceland.","Whole of CFC income"]
["Indonesia","De minimis: Jurisdiction: Control: one or more companies own (directly or indirectly) 50% or more of its total shares or voting rights as at the end of the tax year of the Indonesian shareholders.","none ","Whole of income (deemed dividend)"]
["Ireland","De minimis: accounting profits must be (i)  at least €75,000 or, (ii) at least  10% of operating costs Jurisdiction: Control: resident company has direct or indirect ownership of, or entitlement to, more than 50% of the share capital, voting power or distributions.","actual corporate tax paid by the CFC  is at least 50% of the corporate tax that would have been paid by the CFC on its profits if they were taxed in accordance with the Irish corporation tax system","passive income, connected to significant people functions (SPF) performed in Ireland by the irish, or connected, company, and from non-genuine arrangements put in place for the essential purpose of avoiding tax"]
["Israel","De minimis: either over 50% (i) of the entity’s income during the tax year is passive income or (ii) of the entity’s profits during the tax year are derived from passive income. Jurisdiction: Control: (1) Held at more than 50%, directly or indirectly, by residents or (2) more than 40% of one or more of its means of control is held by residents who, together with a relative of one or more of them, hold more than 50% in one or more of the means of control of the entity or (3) a resident has the right to change substantial managerial decisions",0.15,"passive (deemed dividend)"]
["Italy ","De minimis: one third of revenues must be from passive and limited active (transactions between associates) Jurisdiction: White list on EEA countries only Control: (1) a person holds, directly or indirectly, the majority of the votes at the shareholders’ meeting or (2) sufficient votes to exert a decisive influence in the shareholders’ meeting or (3) the entity is under the dominant influence of another person due to a special contractual relationship or (4) a person holds, directly or indirectly, more than 50% of its profits participation rights substantive economic prescence: worldwide","ETR lower than 50% of the ETR which would apply if it were resident in Italy. No lower than 24%.","CFC income as a whole"]
["Japan","De minimis: Amount subject to partial application is lat least JPY 20 million and at least 5% of total taxable income. Jurisdiction: Control: “having a substantial control relationship”, presumed if foreign related company exists, defined when more than 50% of the shares or interests are directly or indirectly owned by japanese residents or domestic corporations or by foreign corporations that have a substantial relationship with residents or domestic corporations (“Substantial relationship” refers to specific situations when a domestic company has the right to claim almost all of the residual property of the foreign subsidiary or there is a contract that provides that the domestic company has the right to determine how to dispose of the foreign subsidiary’s property), and (1) a Japanese company directly or indirectly holding at least 10% of a foreign related company or  (2) a Japanese company having a substantial controlling relationship over a foreign related company (3) a Japanese company having a substantial controlling relationship over a foreign subsidiary that itself directly or indirectly holds at least 10% of a foreign related company; and (4) a Japanese company for which its parent corporation directly or indirectly holds at least 10% of a foreign related company.","(1) ETR must be less than 20% or (2) if regarded as specified foreign related company (\"paper company\", cashbox company\", \"blacklist company\") less than 30% ","(1) Income as a whole or (2) if passes economic activity test only passive income if not (3) regarded as specified foreign related company "]
["Kazakhstan ","De minimis: Jurisdiction: Blacklist by government, on jurisdictions with (1) CIT rate below 10% or (2) laws on confidentiality of financial information or laws allowing secrecy in respect of the actual owner of property or the income or actual owners, founders or shareholders of a company, except for countries with which Kazakhstan concluded tax treaties with exchange of information provisions, as alternative Control: Resident company hold directly or indirectly at least 25% of the share capital or voting shares in a non-resident legal entity ","ETR 20% ","CFC income as a whole"]
["Korea (rep) ","De minimis: income earned must be more than KRW 200 million (aprox EUR 150 000).  Passive income must exceed 5%. If income is at least 50% active, only passive income is taxed. Jurisdiction: Blacklist Control: taxpayer holds 10% of CFC defined as \"related\" to taxpayer if - (1)taxpayer, with related parties, holds (directly or indirectly) 50% or more of the total outstanding shares of the CFC (2) the taxpayer and the CFC are so-called “sister companies” in the sense that a third party holds (directly or indirectly) 50% or more shares in both companies (3) taxpayer and the CFC share certain “common interest” and either company, or a third party, has the capacity to effectively make business decisions of the other party Substantive economic prescence: worldwide with exceptions","average effective tax for the past three years is 15% or less of actually accrued income","CFC income as a whole (deemed dividend). Only passive income is passed activity test. "]
["Latvia","De minimis: profits must exceed EUR 750,000 and income derived otherwise than from the realization of goods or services (i.e. passive income) must exceed EUR 75,000, unless located or established in a low-tax jurisdiction. Jurisdiction: Blacklist affecting categiries of income, derived by government Control: the taxpayer company, either alone or with related persons, directly or indirectly owns more than 50% of the share capital of, or of the voting power in, or is entitled to more than 50% of profits of, the foreign company.","none ","all income derived from artificial transactions"]
["Lithuania ","De minimis: passive income of a CFC (and active from transactions betwen related parties) exceeds one third of its total income, if not located in blacklisted jurisdiction Jurisdiction: Blacklist regarding income categories Control: a Lithuanian entity by itself, or together with related persons, directly or indirectly holds more than 50% of shares, voting rights or rights to distributed profits or exclusive rights to acquire them. substantive economis prescence: worldwide except blacklisted","ETR is less than 50% of ETR that would have been calculated according to the Lithuanian tax rules.","CFC income as a whole"]
["Luxembourg ","De minimis: accounting profit must be at least EUR 750,000 or exceed 10% of operating profits during a taxable period. Jurisdiction: Control: a Luxembourg parent has a 50% direct (or indirect) participation, ownership, or entitlement to an interest in voting or capital rights or profits. ","ETR lower than 50% of the Luxembourg corporate income tax of the preceding year (17% in 2019 and therefore by reference to a rate of 8.5%).","CFC income as a whole, when it arises from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage."]
["Maldives","De minimis: Jurisdiction: Control: when five or fewer residents of the Maldives hold at least 50% of shares, each person that is a resident of the Maldives and holds a share in the capital of the foreign entity shall include in its taxable income its share of the taxable income of the foreign entity","none ","CFC income as a whole"]
["Malta","De minimis: accounting profits above EUR 750,000 and non-trading income at least EUR 75,000, or accounting profits at least 10% of operating costs in the tax period. Jurisdiction: Control: the Maltese taxpayer itself, or together with associated entities, holds a direct or indirect participation of more than 50% of the voting rights or of the capital, or is entitled to receive more than 50% of the profits of such entity","ETR less than 50% of the ETR that would have been payable by the entity in Malta","Whole of CFC income, to the extent it arises from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage. "]
["Mauritius","De minimis: (1) the tax rate in the country of residence of the CFC is more than 50% of the tax rate in Mauritius or (2) Accounting profits above EUR 750,000 and non-trading income at least EUR 75,000, or accounting profits at least 10% of operating costs in the tax period. Jurisdiction: Control: more than 50% of its total participation rights are held directly or indirectly by the subject resident company or owned by that resident company together with its associated enterprises. “associated enterprise” exists when company or individual holds directly or indirectly a participation in terms of voting rights or capital ownership of 25% or more or is entitled to receive 25% or more of the profits of an entity.","none ","non-distributed CFC income that the Director-General of the Mauritius Revenue Authority considers to have  arised from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax benefit."]
["Mexico ","De minimis: passive income represents more than 20% of the company’s total income Jurisdiction: Control: (1) when the average daily participation of the taxpayer in the foreign company allows him to hold more than 50% of the total voting rights in the company; (2) in case of reduction of capital or liquidation of the foreign company, the taxpayer is entitled to more than 50% of the assets or profits of the foreign company; (3) the taxpayer and the foreign company consolidate their financial statements based on the applicable accounting principles; or (4) the taxpayer has the right, directly or indirectly, to decide on the management of the foreign company.","ETR is lower than 75% of the income tax that would have been incurred and paid in Mexico had the income been generated there.","Whole of CFC income"]
["Mongolia","De minimis: Jurisdiction: Control:  a foreign entity with more than 50% of its shares or voting rights owned directly or indirectly by a resident taxpayer will be considered a controlled foreign company.","n/a","Lacks data"]
["Mozambique","De minimis: Jurisdiction: Control: resident participator owns directly or indirectly: (1) 25% or more of its capital or (2) 10% or more of its capital if more than 50% of the capital is owned directly or indirectly by Mozambican resident participators","ETR is equal to or less than 60% of the Mozambican annual CIT rate, which is 32%","Whole of CFC income"]
["Nepal ","De minimis: Jurisdiction: Control: a resident person holds an interest and controls or may benefit from 50% or more of the rights to income, capital or voting power alone or with not more than four other residents. ","n/a","Whole of CFC income (deemed dividend) - where rights to dividend are not reasonably certain, they are decided in such manner as the Inland Revenue Department thinks appropriate"]
["Netherlands","De minimis:  (1)  at least 30% net amount tainted income or, (2) for financial institutions, more than 30% of tainted income must come from Netherlands or the jurisdiction where the foreign entity is based. Jurisdiction: blacklist: EU's list of non-cooperative jurisdiction - as alternative to low tax approach. Control: the taxpayer (alone, or together with related persons) directly or indirectly holds an interest of more than 50% in the capital, voting rights or an entitlement to the profits substance carve-out: worldwide","CIT is less than 9%","passive income "]
["New Zeeland","De minimis: for taxation of active income, passive income must be at least 5% (active income exemption) Jurisdiction: Control: Residents are taxed when, alone or together with associates, holding an income interest of 10% or more in a CFC, existing when (1) five or fewer residents have 50% associate-inclusive control interest (defined as (a) shareholdings in the foreign company; or (b) shareholder decision-making rights for the foreign company; or (c) rights to receive income from the foreign company; or (d) rights to receive distributions of the company’s net assets.), or (2) a single resident has 40% associate-inclusive control interest, or (3) a group of five or fewer residents has actual control, of the company. ","n/a","Whole of CFC income. If active income exemption applies - only passive income is taxed. "]
["Norway","De minimis: the income of the foreign company must be mainly  (mainly is not defined, but presumed when at least 50% of total gross income is passive) of a passive character (1) If there is a tax treaty between Norway and the foreign country and (2) to the extent that the foreign company is within the scope of the tax treaty Jurisdiction: blacklist set up by the Directorate of Taxes, as alternative to low tax approach Control: Measured on a case by case basis factoring amongst other things contractual relations, power to elect board members or claim veto, entitlement to profits and ownership of capital, but control is automatically presumed when (1) If Norwegian taxpayers (unlimited) directly or indirectly own or control at least 50% of a foreign company control is presumed (2) A foreign company remains Norwegian-controlled for 1 year after the ownership and control dips below 50%. (3) If Norwegian shareholders own or control more than 60% of a foreign company at the end of the year. Indirect control requires only that there is qualifying control at each corporate level rather than control at the level of the relevant foreign company. Substance carve-out: for residents within the EEA in so far as there is an agreement for the exchange of information between Norway and the other country.","ETR is less than two thirds of what would have been due if the company was resident in Norway.","Whole of CFC income"]
["Pakistan","De minimis: At least 20% passive income. Income must exceed PKR 10 million. The shares of the company are not traded on any stock exchange recognized by the law of the country or jurisdiction of which the non-resident company is resident for tax purposes. Jurisdiction: Control: (1) more than 50% of the shares, rights to profits or voting rights of the non-resident company are held, directly or indirectly, by one or more persons (unlimited, without tresholds) resident in Pakistan or more than 40% of the capital or voting rights of the non-resident company are held, directly or indirectly, by a single resident person in Pakistan and (2) the capital or voting rights of the resident in the CFC as defined under (1) must be at least ten percent ","ETR is less than 60% of the tax payable in Pakistan. ","Whole of CFC income (hybrid of deemed dividend/ piercing the veil)"]
["Peru","De minimis: the total amount of the net passive income does not exceed 5 Tax Units (aprox 6750 USD). Passive income of the CFC must be equal to or less than 20% of the total income of the CFC. f the income that qualifies as passive income is equal to or higher than the 80% of the total income of the CFC, the total income will be deemed as passive income. Jurisdiction: blacklist in Appendix 1 of the Income Tax Regulation as alternative to low tax approach Control: the controller alone or with his related parties domiciled in Peru have a direct or indirect participation in more than 50% in the (i) capital, (ii) results or (iii) voting rights of the analysed entity. ","ETR lower than 75% of the income tax that would have been applicable in Peru","passive and limited active income. Whole of CFC income if fails active income test.  "]
["Poland","De minimis:  at least 33% of total income must be “passive” income.  Jurisdiction: Blacklist and CFCs that are located in jurisdictions that do not have an exchange of information agreement with Poland or the European Union as alternatives to control requirement! Control: (1) a resident company holds for an uninterrupted period of a minimum of 30 days, directly or indirectly, at least 50% of the share capital, voting rights or share in profits of the non-resident company. Substance carve-out: EEA jurisdictions","ETR is 50% lower than the tax that would be due from that unit under Polish CIT rules.","Whole of CFC income"]
["Portugal ","De minimis: passive income must exceed 25% of total Jurisdiction: blacklist, as approved by Ministerial Order Control: the shareholder must own, directly or indirectly, or together with related entities (constructive ownership rule), even if through an agent, trustee or interposed person, either 25% or more of shares, voting rights or rights over the income or assets of the foreign resident entity Substance carve-out: EEA","ETR is less than 50% of the tax that would be due in Portugal. Blacklist creates presumtion of low tax. ","Whole of CFC income"]
["Romania","De minimis: more than one third must be passive income. Revenue in previous year must exceed EUR 1 million. Jurisdiction: Control: the Romanian taxpayer by itself or together with its associated enterprises holds a direct or indirect participation of more than 50% of the voting rights or directly or indirectly owns more than 50% of capital or is entitled to receive more than 50% of the profits. Substance carve-out: EU/EAA","ETR is lower than the difference between the corporate tax that would have been charged under the Romanian corporate tax system and the actual corporate tax paid ","passive income"]
["Russia","De minimis: passive income must exceed 20% (the threshold for holding and sub-holding companies is 5%). Profits must be at least RUB 10 million  Jurisdiction: Blacklist based on whether a country effectively exchanges tax information with Russia. Whitelist for Eurasian Economic Union (EEU) Member States. to be taxed, a CFC must fullfill both designated jurisdiction and low tax approach. Control: control via Russian public companies is excluded. (1) direct and/or indirect interest (holds voting right) in a foreign entity exceeding 25%; or (2) direct and/or indirect interest in a foreign entity exceeding 10% provided that, overall, the Russian tax residents hold more than a 50% interest in this entity; or (3) exerts or may exert decisive influence over a foreign entity’s decisions regarding its profit distribution, based on his direct or indirect participation in this entity, participation in a contract (agreement) on this entity management or other specific features of his relationships with the entity (open ended list).  ","ETR is is lower than 75% of the weighted average tax rate under russian law","Whole of CFC income"]
["Slovak republic","De minimis: Jurisdiction: Control: taxpayer by itself, or together with its associated enterprises, holds a direct or indirect participation of more than 50% of the voting rights, or owns directly or indirectly more than 50% of the capital or is entitled to receive more than 50% of the profits of that entity","ETR lower than 50% of the corporate income tax that the entity would pay in the Slovak Republic","Whole of CFC income, to the extent this income is attributable to the assets and risks pertaining to the significant functions performed by this Slovak corporate tax resident controlling the CFC"]
["Slovenia","De minimis: at least one third of income must be passive. Jurisdiction: Control: a company by itself, or together with its related parties holds a direct or indirect participation of more than 50% of the voting rights, or owns directly or indirectly more than 50% of capital or is entitled to more than 50% of the profits of that company Substance carve-out: worldwide","ETR is lower than one half of the corporate income tax that would apply in Slovenia","passive income"]
["South Africa","De minimis: if not a bank, insurer or financial service privider, the total of the amounts arising from financial instruments must exceed 5% Jurisdiction: Control: every resident that, alone or together with their connected persons, holds at least 10% of the participation rights or exercise 10% or more of the voting rights in a CFC, as defined when (1) one or more taxpayerst, alone or together with connected persons, with at least 5% participation rights, directly or indirectly hold more than 50% of total participation rights or exercise directly or indirectly more than 50% of voting rights. Participation rights are defined as the right to participate in all or part of the benefits of the rights attaching to a share. substance carve-out: worldwide","ETR less than 67.5% of what would be payed in South Africa","Whole of CFC income"]
["Spain ","De minimis: Passive income must exceed 15% of income or 4% of the total turnover. Not applied when 50% of the income from rendering services by the CFC is obtained from non-related persons.  Jurisdiction: Control: parent company must own, individually or together with other related/associated companies or individuals, at least 50% of the non-resident subsidiary’s share capital, equity, profits or voting rights substance carve-out: EU/EEA","ETR less than 75% of spannish ETR ","passive income"]
["Sweden","De minimis: Jurisdiction: Complex whitelist exempting CFCs in certain jurisdictions, exept from certain categories of income Control: at least 25% of the capital of, or voting rights in, the foreign legal entity is controlled (de facto control on case by case basis.), directly or indirectly, by the taxpayer alone or together with accosiated companies. Accosiated companies: within common sphere of interest, directly or indirectly own or control at least 25% of the capital or voting rights in the foreign company substance carve-out: EU/EEA","ETR 55 % of, or less than, that of a corresponding income under Swedish law.","Whole of CFC. Except when whitelisted - then only certin categories. "]
["São Tomé and Príncipe","De minimis: Jurisdiction: Control: (1) taxpayer owns directly or indirectly 25% or more of the CFC’s capital or (2) 10% or more of the CFC’s capital, where more than 50% of its capital is owned (directly or indirectly) by Santomean resident shareholders.","ETR is lower than 60% of the tax that would have been paid if such company were resident in São Tomé and Príncipe","Whole of CFC income"]
["Tajikstan ","De minimis: Jurisdiction: blacklist Control: ownership, direct or indirect, of more than 10% of the share capital (or of the voting shares) of a foreign company.","foreign CIT is 30% lower that CIT in Tajikstan ","Whole of CFC income"]
["Tanzania","De minimis: Jurisdiction: Control: a non-resident trust or corporation in which a resident person has an interest, whether directly or indirectly through one or more interposed non-resident entities, and where the person is associated with the trust or corporation","Tanzania Revenue Authority https://www.tra.go.tz/ income tax act 2004 (sections 3 and 73(1) of the ITA).\n","Whole of CFC income"]
["Turkey ","De minimis: 25% of the CFC's gross profits must be passive income. Turnover must exceed TRY 100,000. Jurisdiction: Control: taxpayers holds directly or indirectly at least 50% of the share capital or voting rights or of rights to the profits.","ETR is lower than 10%\n","Whole of CFC income (deemed dividend) "]
["United Kingdom ","De minimis: CFC’s profits must exceed GBP 50,000 for the accounting period in question. if profits representing non-trading income does not exceed GBP 50,000, then total profits must exceed exceed GBP 500,000. Accounting profits must exceed 10% of relevant operating expenditure. Jurisdiction: Whitelist with exceptions Control: UK resident companies are taxable on their actual relevant interests if they are considered to have 25% interests (which may initially include taking into account the interests of related parties, even though those interests do not necessarily then form part of the actual taxable icome) when (1) resident persons (unlimited) have 51% control over a foreign company through shares, voting power or documentary evidence of some sort, including the memorandum and articles of association of the foreign company or (2) UK resident person has at least a 40% interest in a foreign company and, at the same time, a non-UK resident has at least a 40% but not more than a 55% interest or (3)  a UK resident company together with any associated person(s) has directly or indirectly a more than 50% investment in an overseas resident company. An associate in this context means a UK or non-UK resident person (including a company) having directly or indirectly a 25% or more interest in the UK resident company, or when a person and the UK resident company are both directly or indirectly 25% or more invested in by a third party. substance carve-out: EU/EEA ","ETR 75% or lower than corresponding UK tax. ","The CFC charge applies to such of the CFC’s profits as pass through the so-called “CFC charge gateway” - five different tests decide what final income is taxed"]
["United States ","US has two systems of taxing CFCs that can apply simunltainiously, The Subpart F rules and the GILTI regime, see kolumn D.  De minimis: the gross sum of certain tainted income of a CFC for the year must be at least (1) 5% of its gross income or (2) USD 1 million. Jurisdiction: Control: (1) more than 50% of stock is owned, either by voting power or stock value, by “US shareholders” on any day during the taxable year. “US shareholder” (USSH) is defined to include a US citizen, US resident, domestic corporation or domestic partnership that owns (directly, indirectly or constructively) 10% or more of the CFC’s stock. The 10% ownership test will be applied on the basis of either 10% or more of the total combined voting power of all classes of stock of the foreign corporation entitled to vote or 10% or more of the total value of shares of all classes of stock of the foreign corporation. or (2) a foreign corporation will be treated as a CFC if USSHs, in aggregate, possess one or more of the following powers: (i) the power to elect, appoint or replace a majority of that body of persons exercising the powers ordinarily exercised by the board of directors of a domestic corporation; (ii) when the shareholders have the power to elect exactly one half of the members of the governing body of the foreign corporation, the power either to cast the deciding vote in any such election or to exercise the power ordinarily exercised by the governing body during any deadlock that may arise; or (iii) the power to elect, appoint or replace the voting trustee when a voting trust is in place. ","ETR 90% of or lower than highest US CIT rate","Subpart F: passive income and limited active, if not 70% of its gross income is tainted income, then whole of CFC income is taxed. GILTI: whole of CFC income (The calculation starts with all of the CFC’s income (less deductions and taxes) and removes income otherwise taxed by or exempt from tax by the United States, some earnings with a low risk of tax avoidance and a normal return on tangible assets. The remaining amount is deemed to be the USSH’s low-taxed intangible income) GILTI is taxed at a rate of 10.5% and after 2025 13.125%, and credit for foreign tax is limited at 80% "]
["Uruguay","n/a: CFC only for natural persons"]
["Uzbekistan","De minimis: income must exceed UZS 300 million (approximately USD 32,000) no data on active income test Jurisdiction: banks and insurance companies operating in tax treaty jurisdictions are excempt. Control: (1) a company or individual whose direct and/or indirect participation in a foreign company of at least 25% or (2) a company or individual who directly or indirectly owns more than 10% of a foreign company where Uzbek tax residents hold a direct or indirect participation of at least 50%.","none, except with jurisdictions that have a tax treaty with Uzbekistan: if ETR less than the applicable Uzbek corporate income tax rate","Whole of CFC income"]
["Venezuela","De minimis: a maximum of 50% of the total assets representing the investment can consist of fixed assets used in business activities, except when more than 20% of the income from the entity is passive income  Jurisdiction: blacklist Control: the taxpayer has influence over the dividend payment policy of the companies situated in the low-tax jurisdiction, or it has control of its administration either directly or indirectly. The law presumes that the taxpayer has such influence or control if the company distributing the dividends is located in a low-tax jurisdiction (blacklisted or CIT 20% or lower).","CIT of 20% or lower","Whole of CFC income"]