Other taxes on corporations:
Capital duty – No
Payroll tax – No
Real property tax – No
Social security – The employer is required to withhold employee contributions (22.1% of gross salary) from the employee’s gross salary and pay it together with the employer contribution (16.1% of gross salary) each month as part of payroll accounting.
Stamp duty – No
Transfer tax – A special sales tax is levied on motor vehicles (different rates), the transfer of real estate if not subject to VAT (2%) and insurance services (6.5%).
Other – No
Transfer pricing – Rules apply to transactions with nonresident related parties. The rules apply to resident parties only to the extent that one or both parties are deemed to be in a favorable tax position (evidencing tax losses). The arm’s length principle applies and there are documentation and reporting requirements. A party is related if it holds directly or indirectly at least 25% of the other party or if the conditions between them differ from those between unrelated parties.
Thin capitalization – Interest on loans (other than those granted by a bank or an insurance company) is not deductible if (a) received from a shareholder who, at any time during the tax period, directly or indirectly owns at least 25% of the shares in the equity capital or voting rights; and (b) the loan exceeds at any time during the tax period the established debt-to-equity ratio (6:1 for 2008-2010, 5:1 for 2011 and 4:1 from 2012), unless the taxpayer can prove that the loan would have been granted by an unrelated third party. The excess interest is generally recharacterized as a dividend.
Controlled foreign companies – No
Other – General anti-avoidance rules allow the tax authorities to assess tax based on the substance-over-form and economic substance concepts.
Disclosure requirements – None, except for transfer pricing.