🇧🇪 Belgium
Europe & Central Asia · OECD member · ISORA participant · ITTI survey participant
Belgium employs automated bulk data matching in practice and maintains statutory provisions for controlled foreign company rules, interest limitation rules, and country-by-country reporting. The country did not utilize artificial intelligence or machine-learning risk scoring for tax enforcement. In 2022, tax revenue accounted for 42.4% of GDP.Auto-generated summary of the verified data below; every fact traces to a source on this page.
42.4%
tax-to-GDP, general govt (2022, OECD)
9/11
enforcement powers assessed
Where the tax bite lands (2022)
Tax revenue by category, % of GDP, general government — OECD Revenue Statistics (Global).
Who collects it (2022)
| Level of government | % of GDP |
|---|---|
| Central government | 22.2% |
| Social security funds | 13.5% |
| State/regional government | 4.3% |
| State/regional government | 1.9% |
Tax-to-GDP over time
| 2000 | 2010 | 2019 | 2022 |
|---|---|---|---|
| 43.8% | 42.9% | 42.4% | 42.4% |
General government, OECD Revenue Statistics (Global).
Headline statutory rates
As stated in PwC Worldwide Tax Summaries’ territory overview (fetched 2026-08-20) — the wording is PwC’s; source.
| Tax | Headline rate as stated |
|---|---|
| Headline PIT rate | 50 (plus communal taxes ranging between 0% and 9% of the Federal tax rate) |
| Headline CIT rate | 25 |
| Standard VAT rate | 21 |
| Headline individual capital gains tax rate | Capital gains on financial assets (financial instruments, some insurance contracts, crypto assets, and liquidities) accrued as of 1 January 2026 will be taxed at 10% where they exceed EUR 10,000 (draft law). Separate rates and rules will apply for internal capital gains, substantial shareholdings, and capital gains realised out of the scope of the normal management of private estate. |
| Headline corporate capital gains tax rate | Capital gains are subject to the normal CIT rate (except capital gains on shares under certain conditions). |
| WHT rates (%) (Dividends/Interest/Royalties) | Resident and non-resident: 30 / 30 / 30 (but many exemptions or reduced rates exist) |
| Headline net wealth/worth tax rate | Annual tax on securities accounts (version 2.0) levied at a rate of 0.15% on the average value of the account in excess of EUR 1 million. |
| Headline inheritance tax rate | Inheritance tax rate varies depending on the region, the value of the assets inherited, and the relationship between the deceased and the beneficiary. |
| Headline gift tax rate | Gift tax rates vary based on the region where the gift is registered and range between 3% and 7%. NA stands for Not Applicable (i.e. the territory does not have the indicated tax or requirement) NP stands for Not Provided (i.e. the information is not currently provided in this chart) |
Enforcement powers
AI & machine-learning risk scoring No — power absent
Self-reported in the OECD Inventory of Tax Technology Initiatives (2024 Global Survey on Digitalisation).
“Survey question "Administration uses artificial intelligence" — answer: No”
Source: OECD Inventory of Tax Technology InitiativesOECD / IMF survey data · derived from the administration’s own survey answer
Automated bulk data matching Yes — documented practice
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration undertakes fully automated compliance checks based on data matching/analysis" — value: Yes”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Digital platform reporting Yes — statutory power
As an EU member state, bound by Council Directive (EU) 2021/514 (DAC7) to require digital platform operators to collect, verify and report sellers’ income to the tax authority, applicable from 1 January 2023. National implementing law varies; this claim records the EU-law obligation, not a particular national statute.
“Member States shall adopt and publish, by 31 December 2022, the laws, regulations and administrative provisions necessary to comply with this Directive.”
Source: Council Directive (EU) 2021/514 (DAC7) — reporting by digital platform operatorsOfficial source · quote machine-verified 2026-08-25
Crypto-asset reporting Yes — statutory power
As an EU member state, bound by Council Directive (EU) 2023/2226 (DAC8) to require crypto-asset service providers to report users and transactions to the tax authority, applicable from 1 January 2026. National implementing law varies; this claim records the EU-law obligation, not a particular national statute.
“Member States shall adopt and publish, by 31 December 2025, the laws, regulations and administrative provisions necessary to comply with this Directive.”
Source: Council Directive (EU) 2023/2226 (DAC8) — reporting by crypto-asset service providersOfficial source · quote machine-verified 2026-08-25
Citizenship-based taxation No — power absent
Belgium taxes individuals by residence, not citizenship (PwC Worldwide Tax Summaries).
“Belgium taxes its residents on their worldwide income, irrespective of their nationality. Residents of Belgium are taxable on their worldwide income, while non-residents are only taxable on Belgian-source income.”
Source: PwC Worldwide Tax Summaries — BelgiumProfessional / legal analysis · quote machine-verified 2026-08-25
Controlled foreign company (CFC) rules Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there a controlled foreign company rule in place? · Not applicable" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Interest limitation rules Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there an interest limitation rule in place? · Regime 2" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Country-by-country reporting Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (0).
“OECD Corporate Tax Statistics: "Is there a country-by-country reporting law in place?" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Public naming of non-compliant taxpayers No — power absent
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure" — value: No”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Anti-avoidance regime detail (OECD Corporate Tax Statistics)
OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation, CbCR and IP-regime rules.
CFC rules — 13 data points
| Is there a controlled foreign company rule in place? · Regime 1 | Yes |
| Is there a controlled foreign company rule in place? · Not applicable | Yes |
| Controlled foreign company rule · Regime 1 | A foreign company will be considered as a CFC if the following two conditions are simultaneously satisfied: - The control test: the Belgian taxpayer owns (directly or indirectly) the majority of voting rights of the foreign company, or has (directly or indirectly) a stake of at least 50% in the capital of this company, or is entitled to at least 50% of the profits of this company; and - The taxa… |
| Controlled foreign company rule · Not applicable | A foreign company will be considered as a CFC if the following two conditions are simultaneously satisfied: - The control test: the Belgian taxpayer owns with or without its associated entities the majority of the voting rights attached to the total of the shares of the foreign company, or holds together with its associated entities a stake of at least 50% in the capital of this company, or … |
| Significant controlled foreign company exemption and exclusion requirements · Regime 1 | No limitation in function of the size of the participation. No foreign tax credit. But when the CFC distributes profits that have already been subject to tax at the level of the Belgian corporate shareholder, based on the Belgian CFC-rules, these profits shall be fully deducted from the recipient's tax base. |
| Significant controlled foreign company exemption and exclusion requirements · Not applicable | The CFC rules do not apply when: - less than 1/3 of the total income qualifies as passive income (art. 185/2, 4, par. 1, 2nd stripe, BITC 92); - the CFC is a financial enterprise and its passive income comes for one-third or less from transactions with the taxpayer or with the taxpayer's associated entities (art. 185/2, 4, par. 1, 3rd stripe, BITC 92). |
| Controlled foreign company income · Not applicable | DEFINITION: Under article 185/2, § 1, Belgian Income Tax Code 1992 (BITC 92), a “CFC income” is defined as the non-distributed profit of a qualifying PE or CFC (as defined in art. 185/2, § 3, BITC 92) that must be included in the Belgian taxpayer’s taxable base (that are not excluded according to art. 185/2, § 4, BITC 92). It is computed by a 4-steps method detailed in article 185/2, § 2, BITC 92,… |
| Substantial activity requirements description · Not applicable | The CFC rules do not apply if the CFC carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances (art. 185/2, § 4, par. 1, 1st stripe, BITC 92). |
| Substantial activity requirements · Regime 1 | There is no substantial activity carve out. |
| Substantial activity requirements · Not applicable | Yes |
| Trigger rate for controlled foreign company rule · Not applicable | Both a relative and a fixed rate mechanism are applied. According to article 185/2, § 3, BITC 92, Belgium applies a “low taxation” test with a default relative trigger. It states that foreign entities (PEs or companies) are low-taxed if the foreign income tax is below half of the “theoretical Belgian CIT” (Belgian corporate income tax that would be due if it were established in Belgium and compute… |
| Year of introduction of the controlled foreign company rule · Regime 1 | 2017 |
| Year of introduction of the controlled foreign company rule · Not applicable | 2024 |
Interest limitation — 119 data points
| Number of years allowed under carry forward/back. · Regime 1 | indefinitely |
| Number of years allowed under carry forward/back. · Rule 1 | indefinitely |
| Do any loss carry-back or carry-forward provisions apply? · Regime 1 | Yes |
| Do any loss carry-back or carry-forward provisions apply? · Regime 2 | No |
| Do any loss carry-back or carry-forward provisions apply? · Regime 3 | No |
| Do any loss carry-back or carry-forward provisions apply? · Rule 1 | Yes |
| Do any loss carry-back or carry-forward provisions apply? · Rule 2 | No |
| Do any loss carry-back or carry-forward provisions apply? · Rule 3 | No |
| Is a de minimis threshold present? · Regime 1 | yes: 3 million euros |
| Is a de minimis threshold present? · Regime 2 | N |
| Is a de minimis threshold present? · Regime 3 | N |
| Is a de minimis threshold present? · Rule 1 | EUR 3 million |
| Is a de minimis threshold present? · Rule 2 | None |
| Is a de minimis threshold present? · Rule 3 | None |
| Any other exclusions? · Regime 1 | Yes |
| Any other exclusions? · Regime 2 | No |
| Any other exclusions? · Regime 3 | No |
| Any other exclusions? · Rule 1 | Yes |
| Any other exclusions? · Rule 2 | No |
| Any other exclusions? · Rule 3 | No |
| Exclusions based on payer characteristics? · Regime 1 | Yes |
| Exclusions based on payer characteristics? · Regime 2 | No |
| Exclusions based on payer characteristics? · Regime 3 | No |
| Exclusions based on payer characteristics? · Rule 1 | Yes |
| Exclusions based on payer characteristics? · Rule 2 | No |
| Exclusions based on payer characteristics? · Rule 3 | No |
| Exclusions based on payment characteristics? · Regime 1 | Yes |
| Exclusions based on payment characteristics? · Regime 2 | Yes |
| Exclusions based on payment characteristics? · Regime 3 | Yes |
| Exclusions based on payment characteristics? · Rule 1 | Yes |
| Exclusions based on payment characteristics? · Rule 2 | Yes |
| Exclusions based on payment characteristics? · Rule 3 | Yes |
| Exclusions based on recipient characteristics? · Regime 1 | Yes |
| Exclusions based on recipient characteristics? · Regime 2 | Yes |
| Exclusions based on recipient characteristics? · Regime 3 | Yes |
| Exclusions based on recipient characteristics? · Rule 1 | Yes |
| Exclusions based on recipient characteristics? · Rule 2 | Yes |
| Exclusions based on recipient characteristics? · Rule 3 | Yes |
| Financial accounting measure applied to rule · Regime 1 | interest-to-EBITDA |
| Financial accounting measure applied to rule · Regime 2 | Debt-to-equity |
| Financial accounting measure applied to rule · Regime 3 | price-based (market-rate) cap |
| Financial accounting measure applied to rule · Rule 1 | interest-to-EBITDA |
| Financial accounting measure applied to rule · Rule 2 | Debt-to-equity |
| Financial accounting measure applied to rule · Rule 3 | price-based (market-rate) cap |
| Description of group ratio rule · Regime 2 | As mentioned above, interests paid in the context of intra-group loans concluded before 17 June 2016 are also subject to the 5:1 debt-to-equity ratio rule, such interests being only deductible in the extent that the amount of tainted" debt is five times inferior or equal to the amount of equity (see article 198, 1, 11 /1, CIR 92). |
| Description of group ratio rule · Rule 2 | As mentioned above, interests paid in the context of intra-group loans concluded before 17 June 2016 are also subject to the 5:1 debt-to-equity ratio rule, such interests being only deductible in the extent that the amount of “tainted" debt is five times inferior or equal to the amount of equity (see article 198, § 1, 11°/1, CIR 92). |
| Is there a group ratio rule or similar type of rule in place? · Regime 1 | No |
| Is there a group ratio rule or similar type of rule in place? · Regime 2 | Yes |
| Is there a group ratio rule or similar type of rule in place? · Regime 3 | No |
| Is there a group ratio rule or similar type of rule in place? · Rule 1 | No |
| Is there a group ratio rule or similar type of rule in place? · Rule 2 | Yes |
| Is there a group ratio rule or similar type of rule in place? · Rule 3 | No |
| Is there an interest limitation rule in place? · Regime 1 | Yes |
| Is there an interest limitation rule in place? · Regime 2 | Yes |
| Is there an interest limitation rule in place? · Regime 3 | Yes |
| Is there an interest limitation rule in place? · Rule 1 | Yes |
| Is there an interest limitation rule in place? · Rule 2 | Yes |
| Is there an interest limitation rule in place? · Rule 3 | Yes |
| Can interest be recharacterised as a dividend? · Regime 1 | No |
| Can interest be recharacterised as a dividend? · Regime 2 | No |
| Can interest be recharacterised as a dividend? · Regime 3 | No |
| Can interest be recharacterised as a dividend? · Rule 1 | No |
| Can interest be recharacterised as a dividend? · Rule 2 | No |
| Can interest be recharacterised as a dividend? · Rule 3 | No |
| Is the rule is applicable to net or gross interest expensing? · Regime 1 | Net interest expense |
| Is the rule is applicable to net or gross interest expensing? · Regime 2 | Gross interest expense |
| Is the rule is applicable to net or gross interest expensing? · Regime 3 | Gross interest expense |
| Is the rule is applicable to net or gross interest expensing? · Rule 1 | Net interest expense |
| Is the rule is applicable to net or gross interest expensing? · Rule 2 | Gross interest expense |
| Is the rule is applicable to net or gross interest expensing? · Rule 3 | Gross interest expense |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Regime 1 | The following 4 mechanisms apply only for companies or PEs that are members of a Belgian group: 1) the 3 million euros "de-minimis" threshold is shared across Belgian group members (article 198/1, 3, 1st stripe, BITC 92); 2) intra-Belgian-group interest is eliminated from the EBC calculation (article 198/1, 2, par. 3, BITC 92); 3) intra-Belgian-group interest is eliminated from the EBITDA c… |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Regime 3 | Interest under a centralised cash-pool framework paid to a related company is not subject to the MFI+2.5% ceiling (still must be arm s-length) |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Rule 1 | The following 4 mechanisms apply only for companies or PEs that are members of a Belgian group: 1) the 3 million euros "de-minimis" threshold is shared across Belgian group members (article 198/1, § 3, 1st stripe, BITC 92); 2) intra-Belgian-group interest is eliminated from the EBC calculation (article 198/1, § 2, par. 3, BITC 92); 3) intra-Belgian-group interest is eliminated from the EBITDA calc… |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Rule 3 | Interest under a centralised cash-pool framework paid to a related company is not subject to the MFI+2.5% ceiling (still must be arm’s-length) |
| Is the rule applicable to related party debt? · Regime 1 | No |
| Is the rule applicable to related party debt? · Regime 2 | No |
| Is the rule applicable to related party debt? · Regime 3 | Yes |
| Is the rule applicable to related party debt? · Rule 1 | No |
| Is the rule applicable to related party debt? · Rule 2 | No |
| Is the rule applicable to related party debt? · Rule 3 | Yes |
| Description of interest limitation rule · Regime 1 | The interest-limitation rule as introduced in article 198/1, BITC 92, limits the deductible exceeding borrowing costs (EBC) up to the highest amount of either 30 % of tax-adjusted EBITDA, or 3 million euros (which therefore constitues a "de minimis" threshold). EBC are the net financing costs (or net interest expense), which are the borrowing costs minus interest, or any economically equivalent … |
| Description of interest limitation rule · Regime 2 | Interest paid/owned to related parties and/or lenders in tax havens is only deductible to the extent that the amount of tainted" debt is five times inferior or equal to the amount of equity. The rule still applies after June 2016 if the interest is paid to tax havens (see article 198, 1, 11 , BITC 92). The same 5:1 debt-to-equity rule applies for loans concluded before 17 June 2016 where the b… |
| Description of interest limitation rule · Regime 3 | To be deductible, interests must be arm s-length; for non-mortgage, no-fixed-term loans, Belgium applies a ceiling equal to the NBB MFI rate (specific category) + 2.5% excess is non-deductible (see article 55, BITC 92) |
| Description of interest limitation rule · Rule 1 | The interest-limitation rule as introduced in article 198/1, BITC 92, limits the deductible exceeding borrowing costs (EBC) up to the highest amount of either 30 % of tax-adjusted EBITDA, or 3 million euros (which therefore constitues a "de minimis" threshold). EBC are the net financing costs (or net interest expense), which are the borrowing costs minus interest, or any “economically equivalent” … |
| Description of interest limitation rule · Rule 2 | Interest paid/owned to related parties and/or lenders in tax havens is only deductible to the extent that the amount of “tainted" debt is five times inferior or equal to the amount of equity. The rule still applies after June 2016 if the interest is paid to tax havens (see article 198, § 1, 11°, BITC 92). The same 5:1 debt-to-equity rule applies for loans concluded before 17 June 2016 where the be… |
| Description of interest limitation rule · Rule 3 | To be deductible, interests must be arm’s-length; for non-mortgage, no-fixed-term loans, Belgium applies a ceiling equal to the NBB MFI rate (specific category) + 2.5%—excess is non-deductible (see article 55, BITC 92) |
| Type of interest limitation rule · Regime 1 | fixed ratio rule |
| Type of interest limitation rule · Regime 2 | Thin cap |
| Type of interest limitation rule · Regime 3 | rate cap (arm's length) limitation rule |
| Type of interest limitation rule · Rule 1 | fixed ratio rule |
| Type of interest limitation rule · Rule 2 | Thin cap |
| Type of interest limitation rule · Rule 3 | rate cap (arm's length) limitation rule |
| Financial ratio referenced · Regime 1 | 0.3 |
| Financial ratio referenced · Regime 2 | 0.20902777777777778 |
| Financial ratio referenced · Regime 3 | N.A. (it's a price cap: deductible interest ? NBB MFI November rate + 2.5 percentage points) |
| Financial ratio referenced · Rule 1 | 30% |
| Financial ratio referenced · Rule 2 | 5:1 |
| Financial ratio referenced · Rule 3 | N.A. (it's a price cap: deductible interest ≤ NBB MFI November rate + 2.5 percentage points) |
| Is the rule is applicable to third party debt? · Regime 1 | No |
| Is the rule is applicable to third party debt? · Regime 2 | No |
| Is the rule is applicable to third party debt? · Regime 3 | Yes |
| Is the rule is applicable to third party debt? · Rule 1 | No |
| Is the rule is applicable to third party debt? · Rule 2 | No |
| Is the rule is applicable to third party debt? · Rule 3 | Yes |
| Description of targeted rules · Regime 1 | Intra-Belgian group neutralisation (anti-fragmentation): interest between Belgian group members is ignored in the EBC/EBITDA math, and the 3 million euros de-minimis threshold is shared across Belgian group entities, to prevent safe-harbour splitting; Sector/project carve-outs (targeted scoping): financial undertakings and EU long-term public infrastructure projects are carved out of the EBITDA… |
| Description of targeted rules · Regime 2 | it is a back-to-back / guarantee look-through (anti-avoidance) rule : if a loan is guaranteed by a third party or that third party provides the funds to the lender, and this is mainly to obtain a tax-avoidance result, that third party is deemed the beneficial owner for applying the 5:1 test (see article 198, 3, BITC 92). |
| Description of targeted rules · Regime 3 | To be complete, the remaining "targeted rules" are not "interest limitation" rules as such. They would rather fall into the category of "interest disallowance" rules. However, since they apply to interest deductions in a way that the deduction denial functions as a practical limit, we should also mention them. Here below is a short description : Abnormal or gratuitous advantages (article 26, BI… |
| Description of targeted rules · Rule 1 | • Intra-Belgian group neutralisation (anti-fragmentation): interest between Belgian group members is ignored in the EBC/EBITDA math, and the 3 million euros de-minimis threshold is shared across Belgian group entities, to prevent safe-harbour splitting; • Sector/project carve-outs (targeted scoping): financial undertakings and EU long-term public infrastructure projects are carved out of the EBITD… |
| Description of targeted rules · Rule 2 | it is a back-to-back / guarantee look-through (anti-avoidance) rule : if a loan is guaranteed by a third party or that third party provides the funds to the lender, and this is mainly to obtain a tax-avoidance result, that third party is deemed the beneficial owner for applying the 5:1 test (see article 198, § 3, BITC 92). |
| Description of targeted rules · Rule 3 | To be complete, the remaining "targeted rules" are not "interest limitation" rules as such. They would rather fall into the category of "interest disallowance" rules. However, since they apply to interest deductions in a way that the deduction denial functions as a practical limit, we should also mention them. Here below is a short description : • Abnormal or gratuitous advantages (article 26, BIT… |
| Are there targeted rules to address specific risks not addressed by the general rule? · Regime 1 | Yes |
| Are there targeted rules to address specific risks not addressed by the general rule? · Regime 2 | Yes |
| Are there targeted rules to address specific risks not addressed by the general rule? · Regime 3 | Yes |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 1 | Yes |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 2 | Yes |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 3 | Yes |
| Year of introduction of the interest limitation rule · Rule 1 | 2019 |
| Year of introduction of the interest limitation rule · Rule 2 | 2012 |
| Year of introduction of the interest limitation rule · Rule 3 | 2020 |
Country-by-country reporting — 4 data points
| Is there a country-by-country reporting law in place? | Yes |
| Deadline by which filings must be submitted | 12 months |
| Reports are required for MNEs with annual revenues above | EUR 750 million |
| Headquarter jurisidiction filing required from | 01-Jan-16 |
IP regimes — 6 data points
| Further information · Regime 1 | Qualifying assets refers to patents and supplementary protection certificates. Copyrighted computers programs (software). Plant variety rights. Orphan drugs. |
| Regime name · Regime 1 | Patent income deduction |
| Status of the IP regime as determined by the OECD’s Forum on Harmful Tax Practices (FHTP). · Regime 1 | Not harmful (amended) |
| Asset types that can qualify for the IP regime · Regime 1 | Patents, Software |
| Tax rate that would otherwise apply · Regime 1 | 25.00% |
| Reduced tax rate that applies under the IP regime · Regime 1 | 3.76% |
Effective corporate tax rates
| Measure | Year | Rate |
|---|---|---|
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 20.3% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 13.9% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 18.9% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 22.2% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 17.8% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 21.4% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 28.7% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 24.2% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 21.9% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 21.9% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 24.5% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 25.5% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 23.4% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 23.3% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 21.8% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 23.1% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 70.4% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 25.7% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 2.4% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 2.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 28.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 37.6% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 19.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 17.8% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 4.5% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 16.2% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 4.6% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 3.4% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 2.7% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 2.7% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 3.4% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 4.1% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 3.6% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 3.5% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 3.1% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 3.5% |
OECD Corporate Tax Statistics, baseline scenario.
Administration self-reported metrics (ISORA)
Reported by the administration itself to the IMF/OECD/CIAT/IOTA International Survey on Revenue Administration. 1 = yes, 0 = no for policy questions.
| Indicator | Year | Value |
|---|---|---|
| Percentage of tax returns - Electronic, not prefilled - CIT | 2024 | 99.91905163301622 |
| Percentage of tax returns - Electronic, not prefilled - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, not prefilled - VAT | 2024 | 99.70132602059053 |
| Population per FTE | 2024 | 716.96553808948 |
| Labor force per FTE | 2024 | 326.9169286577993 |
| Corporate taxpayers per FTE in LTO/P | 2024 | 41.4438202247191 |
| Active taxpayers on PIT register as percentage of Population | 2024 | 68.35554082645437 |
| Active taxpayers on PIT register as percentage of Labor Force | 2024 | 149.911377521034 |
| Closing stock of collectable arrears as percentage of closing stock of arrears | 2024 | 13.77724244031313 |
| CIT arrears as percentage of CIT collected | 2024 | 28.23686622103781 |
| PIT arrears as percentage of PIT collected | 2024 | 3.952802773868846 |
| PAYE arrears as percentage of PIT collected | 2024 | 0.7190487070477387 |
| VAT arrears as percentage of VAT collected | 2024 | 29.16985961614019 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - PIT | 2021 | 35.99169874 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - PIT | 2021 | 58.28861161 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - VAT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - VAT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - VAT | 2021 | 0 |
| Additional assessments raised through all audits and verification actions as percentage of tax collections | 2024 | 7.183887315329902 |
| Audit hit rate | 2024 | 25.37500052372285 |
| Percentage of tax returns - Electronic, not prefilled - PAYE | 2024 | — |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, not modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PIT | 2024 | 57.11212185686759 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PIT | 2024 | 35.89105004796765 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PAYE | 2024 | — |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PAYE | 2024 | — |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - VAT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - VAT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - PIT | 2024 | 93.00317190483524 |
| Percentage of tax returns - Electronic, prefilled Total - PAYE | 2024 | — |
| Percentage of tax returns - Electronic, prefilled Total - VAT | 2024 | 0 |
| Availability of specific powers in legislation / regulation to assist in collecting tax arrears | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Common administrative penalty framework for non-disclosure across the major tax types | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Penalties imposed generally take account of taxpayers' culpability (i.e. degree of blame) | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to remit / reduce penalties in appropriate circumstances | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure | 2022 | 0 |
| On-time filing rate % - CIT | 2024 | 82.86487014226573 |
| On-time filing rate % - PIT | 2024 | 86.6222955120869 |
| On-time filing rate % - VAT | 2024 | 82.20483114145276 |
| On-time filing rate % - PAYE | 2024 | — |
| Administration pre-fills PIT returns or assessments | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Income information: Wages and salaries | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Income information: Pension | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Taxpayer personal information | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Expense information: Donations | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Expense information: Childcare expenses | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Expense information: Certain insurance premiums | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Expense information: Pension/retirement contributions and savings | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Expense information: Interest on loans and mortgages | 2024 | 1 |
| Administration conducts random audits | 2022 | 1 |
| E-filing mandatory - CIT | 2022 | 1 |
| E-filing mandatory - PIT | 2022 | 0 |
| E-filing mandatory - Employer Withholdings | 2022 | 1 |
| E-filing mandatory - VAT | 2022 | 1 |
| E-payment mandatory - CIT | 2022 | 1 |
| E-payment mandatory - PIT | 2022 | 1 |
| E-payment mandatory - Employer Withholdings | 2022 | 1 |
| E-payment mandatory - VAT | 2022 | 1 |
| Employers withholding taxes on behalf of salaried employees | 2024 | 1 |
| Percentage of payments received electronically-By number of payments | 2024 | 100 |
| Percentage of payments received electronically-By value of payments | 2024 | 100 |
| Cooperative compliance approach exists for -Large taxpayers | 2024 | 1 |
| Cooperative compliance approach exists for -HNWI taxpayers | 2024 | 1 |
| Cooperative compliance approach exists for -Other taxpayers | 2024 | 1 |
| Most employees that have tax deducted through direct withholding required to file a return | 2024 | 1 |
| Administration receives data from devices that register transactions | 2024 | 1 |
| Administration uses electronic compliance checks as part of returns filing process | 2024 | 1 |
| Administration has specialized audit staff for international tax issues | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Customs data | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from stock exchanges | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from the Social Security Agency | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from online (internet-based) vendors | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from Utilities | 2022 | 0 |
| Administration checks the quality of data reported by third parties on a systematic basis | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data on property ownership and sales | 2022 | 1 |
| Administration undertakes fully automated compliance checks based on data matching/analysis | 2022 | 1 |
| Administration undertakes fully automated compliance checks - compliance issues automatically communicated to taxpayer | 2022 | 1 |
| Administration measures the effectiveness of any compliance interventions undertaken | 2022 | 1 |
| Administration has standards for auditor productivity | 2022 | 0 |
Tax technology survey answers (OECD ITTI)
| Question | Answer |
|---|---|
| Personal income tax returns are automatically prefilled with income information | Yes |
| Personal income tax returns are automatically prefilled with expense/allowance information | Yes |
| Administration requires individuals to use an approved digital identity to access secure digital services | Yes |
| Administration requires businesses to use an approved digital identity to access secure digital services | Yes |
| Administration automatically prefills personal income tax returns with data that it has collected | Yes |
| Administration automatically prefills corporate income tax returns with data that it has collected | No |
| Administration automatically prefills value added tax returns with data that it has collected | No |
| For certain personal income taxpayers, the administration prefills tax returns with all necessary data so that they do not need to change the return | Yes |
| Digital identities provided for individuals are interoperable (if several bodies can provide a digital identity) | Yes |
| Digital identities for businesses are interoperable (if several bodies can provide a digital identity) | Yes |
| Approved digital identity offered by the administration for businesses can also be used to access secure digital services from another government body | Yes |
| Approved digital identity offered by the administration for businesses can also be used to access secure digital services from a private sector body | No |
| Estimated percentage of the individual taxpayer population that uses an approved digital identity to access secure digital services offered by the administration | 81-100% |
| Estimated percentage of the business taxpayer population that uses an approved digital identity to access secure digital services offered by the administration | 81-100% |
| Online marketplaces (incl. sharing and gig economy) | No |
| Other online platforms, e.g. stock trading, currencies (incl. crypto). | No |
| Taxpayer accounting systems | No |
| E-invoicing systems | No |
| Online cash registers | No |
| Other government entities | Yes |
| Private entities such as banks and insurance companies | Yes |
| Other jurisdictions (beyond data received under CRS, FATCA and DAC) | No |
| Administration has a comprehensive data management strategy | Yes |
| Administration assesses data quality of reported data | Yes |
| Administration has in place a data ethics framework | Yes |
| Administration controls user data access and security | Yes |
| Administration automatically detects unauthorised access | No |
| Administration employs a Data Privacy Officer | Yes |
| Administration has a cyber security unit | Yes |
| Administration hires external parties to test the security of its systems | Yes |
| Administration uses artificial intelligence as part of the data governance process | No |
| Administration has big data capabilities with the necessary people, skills and infrastructure | Yes |
| Administration uses an enterprise-wide Business Intelligence and Visualisation tool | Yes |
| Administration uses analytics for real-time tax fraud detection and prevention | No |
| Underlying digital identity solution for individuals is built upon an existing domestic identity system or completely new | Existing domestic identity system |
| Underlying digital identity solution for businesses is built upon an existing domestic identity system or completely new | Existing domestic identity system |
| Cloud storage | Yes |
| Robotic process automation | No |
| Artificial intelligence | No |
| Machine learning | Yes |
| Network analysis | Yes |
| DataOps approach | No |
| Industry, international or other framework was adopted for the development of the digital identity solution for individuals | Yes, for the whole digital identity solution |
| Industry, international or other framework was adopted for the development of the digital identity solution for businesses | Yes, for the whole digital identity solution |
| Digital identity solution for individuals can connect with foreign identity systems | No |
| Digital identity solution for businesses can connect with foreign identity systems | No |
| Digital identity for individuals created automatically or on request | On request |
| Digital identity for businesses created automatically or on request | On request |
| Meeting needed to finalise the process of receiving a digital identity for individuals | Always |
| Meeting needed to finalise the process of receiving a digital identity for businesses | Always |
| Individuals without ID-documents or birth certificates can receive a digital identity for the use of tax purpose | No |
| Authentication method applied to verify the digital identity when used online | Yes |
| Use of emerging and innovative technologies or solutions with respect to the main digital identity used by taxpayers | No |
| Administration offers online service for registering for tax (CIT) | Yes |
| Administration offers online service for registering for tax (PIT) | Yes |
| Administration offers online service for registering for tax (VAT) | Yes |
| Administration offers online service for filing tax returns (CIT) | Yes |
| Administration offers online service for filing tax returns (PIT) | Yes |
| Administration offers online service for filing tax returns (VAT) | Yes |
| Administration offers online service for making tax payments (CIT) | Yes |
| Administration offers online service for making tax payments (PIT) | Yes |
| Administration offers online service for making tax payments (VAT) | Yes |
| Administration offers online service for requesting extensions of deadlines (filing and payment) (CIT) | No |
| Administration offers online service for requesting extensions of deadlines (filing and payment) (PIT) | No |
| Administration offers online service for requesting extensions of deadlines (filing and payment) (VAT) | No |
| Administration offers online service for asking for tax payment arrangements (CIT) | No |
| Administration offers online service for asking for tax payment arrangements (PIT) | Yes |
| Administration offers online service for asking for tax payment arrangements (VAT) | No |
| Administration offers online service for asking confidential enquiries in a secure environment (CIT) | No |
| Administration offers online service for asking confidential enquiries in a secure environment (PIT) | No |
| Administration offers online service for asking confidential enquiries in a secure environment (VAT) | No |
| Administration offers online service for filing tax related objections (CIT) | No |
| Administration offers online service for filing tax related objections (PIT) | Yes |
| Administration offers online service for filing tax related objections (VAT) | No |
| Administration offers online service for dealing with correspondence (CIT) | Yes |
| Administration offers online service for dealing with correspondence (PIT) | Yes |
| Administration offers online service for dealing with correspondence (VAT) | No |
| Administration offers online service for uploading data into the tax administration's system (CIT) | Yes |
| Administration offers online service for uploading data into the tax administration's system (PIT) | Yes |
| Administration offers online service for uploading data into the tax administration's system (VAT) | Yes |
| Administration offers specific approaches to those that do not have online access | Yes |
| Administration offers facility for taxpayers to interact with virtual assistants, such as chatbots | No |
| Administration uses artificial intelligence during interactions with taxpayers (other than virtual assistants) | No |
| Administration offers services that follow a set of pre-programmed and automated service responses during interactions with taxpayers (other than virtual assistants) | No |
| Administration makes a library of APIs publicly available for third party use | No |
| Jurisdiction simplified tax rules to allow for the prefilling of returns with all necessary data | Yes |
| Administration has an enterprise data management (governance) system that allows taxpayer information be viewed across the administration | No |
| Administration uses big data for analytical purposes | Yes |
| Administration uses artificial intelligence / machine learning as part of the big data analysis | No |
| Administration uses artificial intelligence | No |
| Administration uses Distributed Ledger Technology, e.g. blockchain, in its taxation processes | No |
| Mobile app | Yes |
| Re-validating the digital identity | Yes |
| Use of big data to: Improve compliance | Yes |