Map: 2023 Global Corporate Income Tax Rates

Jurisdictions Below 15%

Jurisdictions in the map  above with a headline corporate income tax rate below the Pillar Two 15% rate are:

Andorra – 10% (Article 41 of Legislative decree of 5-6-2019 publishing the revised text of Law 95/2010, of 29 December, on corporate tax)

Anguilla – 0% (No Corporate Income Tax System)

Bahamas – 0% (No Corporate Income Tax System)

Bahrain – 0% (No Standard Corporate Income Tax System)

Barbados – 5.5% (Section 43 of the Income Tax Act (as amended)

Bermuda – 0% (No corporate income tax system)

Bosnia and Herzegovina – 10% (Article 36 of the Law on Profit Tax)

BVI – 0% (No corporate income tax system)

Bulgaria – 10% (Article 20 of the Income Tax Law)

Cayman Islands  – 0% (No corporate income tax system)

Cyprus – 12.5% (Schedule 2 of the Income Tax Law)

Gibraltar – 12.5% (Section 6 of the Rates of Tax Rules, 1989)

Guernsey – 0% (Schedule 5 of the The Income Tax (Guernsey) Law, 1975 )

Hungary – 9% (Section 19 of LXXXI of 1996, law on corporate tax and dividend tax)

Ireland – 12.5% (Section 21 of the  Taxes Consolidation Act, 1997 )

Isle of Man – 0% (Income Tax (Corporate Taxpayers) Act 2006)

Jersey – 0% (Section 1 of the Income Tax (Jersey) Law 1961)

Kosovo – 10% (Article 7 of the Law on Corporate Income Tax)

Kyrgyzstan – 10% (Article 240 of the State Tax Code)

Liechtenstein – 12.5% (Article 61 of the Law on State and Municipal Taxes)

Macau – 12% (Schedule to the Complementary Income Tax Law)

Marshall Islands – 0% (No corporate income tax system)

Moldova – 12% (Article 15 of the Fiscal Code)

Montenegro – 9% (Article 28 of the Law on Corporate Income Tax)

North Macedonia  – 10% (Article 2 of the Profit Tax Law)

Palau – 0% (No corporate income tax system)

Paraguay – 10% (Article 21 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System)

Qatar – 10% (Article 9 of the Income Tax Law)

Timor-Leste – 10% (Schedule 6 of the Taxes and Duties Act)

Turkmenistan – 8% (Article 172 of the Uniform Law of Turkmenistan on Taxes)

Turks and Caicos Islands – 0% (No corporate income tax system)

United Arab Emirates – 0%/9% from June 1, 2023 (Article 3 of the Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses)

Vanuatu – 0% (No corporate income tax system)

However, just because the headline corporate income tax rate is below the 15% global minimum rate doesn’t necessarily mean that there would be top-up tax under Pillar Two.

Similarly, just because the headline rate is above 15% doesn’t mean that there would be no Pillar Two top-up tax.

This is because the 15% global minimum rate under Pillar Two is based on the effective tax rate. And not just any effective tax rate, but the effective tax rate determined under Article 5 of the Pillar Two Model GloBE Rules.

Headline vs Effective Tax Rate