🏢 CFC RULE COUNTRIES
59 jurisdictions with Controlled Foreign Corporation anti-avoidance rules
🏢 ALL CFC RULE JURISDICTIONS (59)
These countries have Controlled Foreign Corporation (CFC) rules that may tax residents on passive or undistributed income of foreign companies they control. Critical for structuring international business and investments.
| Country | System | PIT | CIT | Regime |
|---|---|---|---|---|
| 🇷🇺 Russia | Worldwide | 22.0% | 25.0% | |
| 🇨🇦 Canada | Worldwide | 33.0% | 15.0% | |
| 🇨🇳 China | Worldwide | 45.0% | 25.0% | 🏷️ |
| 🇺🇸 United States | Citizenship based | 37.0% | 21.0% | |
| 🇧🇷 Brazil | Worldwide | 27.5% | 34.0% | |
| 🇦🇺 Australia | Worldwide | 45.0% | 30.0% | |
| 🇮🇳 India | Worldwide | 30.0% | 25.2% | 🏷️ |
| 🇦🇷 Argentina | Worldwide | 35.0% | 35.0% | |
| 🇰🇿 Kazakhstan | Worldwide | 15.0% | 20.0% | |
| 🇲🇽 Mexico | Worldwide | 35.0% | 30.0% | |
| 🇮🇩 Indonesia | Worldwide | 35.0% | 22.0% | |
| 🇵🇪 Peru | Worldwide | 30.0% | 29.5% | |
| 🇿🇦 South Africa | Worldwide | 45.0% | 27.0% | |
| 🇨🇴 Colombia | Worldwide | 39.0% | 35.0% | |
| 🇳🇬 Nigeria | Worldwide | 25.0% | 30.0% | |
| 🇻🇪 Venezuela | Worldwide | 34.0% | 34.0% | |
| 🇹🇷 Turkey | Worldwide | 40.0% | 25.0% | |
| 🇨🇱 Chile | Worldwide | 40.0% | 27.0% | 🏷️ |
| 🇫🇷 France | Worldwide | 45.0% | 25.0% | |
| 🇺🇦 Ukraine | Worldwide | 18.0% | 18.0% | |
| 🇪🇸 Spain | Worldwide | 47.0% | 25.0% | 🏷️ |
| 🇸🇪 Sweden | Worldwide | 52.0% | 20.6% | |
| 🇯🇵 Japan | Worldwide | 45.0% | 23.2% | 🏷️ |
| 🇩🇪 Germany | Worldwide | 45.0% | 15.8% | |
| 🇫🇮 Finland | Worldwide | 44.0% | 20.0% | |
| 🇳🇴 Norway | Worldwide | 47.4% | 22.0% | |
| 🇵🇱 Poland | Worldwide | 32.0% | 19.0% | |
| 🇮🇹 Italy | Worldwide | 43.0% | 24.0% | 🏷️ |
| 🇪🇨 Ecuador | Worldwide | 37.0% | 25.0% | |
| 🇳🇿 New Zealand | Worldwide | 39.0% | 28.0% | 🏷️ |
| 🇬🇧 United Kingdom | Worldwide | 45.0% | 25.0% | |
| 🇷🇴 Romania | Worldwide | 10.0% | 16.0% | 🏷️ |
| 🇬🇷 Greece | Worldwide | 44.0% | 22.0% | 🏷️ |
| 🇧🇬 Bulgaria | Worldwide | 10.0% | 10.0% | |
| 🇮🇸 Iceland | Worldwide | 46.2% | 20.0% | |
| 🇰🇷 South Korea | Worldwide | 45.0% | 25.0% | |
| 🇭🇺 Hungary | Worldwide | 15.0% | 9.0% | |
| 🇵🇹 Portugal | Worldwide | 48.0% | 21.0% | 🏷️ |
| 🇷🇸 Serbia | Worldwide | 10.0% | 15.0% | |
| 🇦🇹 Austria | Worldwide | 55.0% | 23.0% | |
| 🇨🇿 Czech Republic | Worldwide | 23.0% | 21.0% | |
| 🇮🇪 Ireland | Worldwide | 40.0% | 12.5% | 🏷️ |
| 🇱🇹 Lithuania | Worldwide | 32.0% | 17.0% | |
| 🇱🇻 Latvia | Worldwide | 33.0% | 20.0% | |
| 🇭🇷 Croatia | Worldwide | 35.4% | 18.0% | 🏷️ |
| 🇸🇰 Slovakia | Worldwide | 35.0% | 21.0% | |
| 🇪🇪 Estonia | Worldwide | 22.0% | 22.0% | 🏷️ |
| 🇩🇰 Denmark | Worldwide | 60.5% | 22.0% | 🏷️ |
| 🇳🇱 Netherlands | Worldwide | 49.5% | 25.8% | 🏷️ |
| 🇧🇪 Belgium | Worldwide | 50.0% | 25.0% | |
| 🇮🇱 Israel | Worldwide | 50.0% | 23.0% | 🏷️ |
| 🇸🇮 Slovenia | Worldwide | 50.0% | 22.0% | |
| 🇨🇾 Cyprus | Worldwide | 35.0% | 12.5% | 🏷️ |
| 🇱🇺 Luxembourg | Worldwide | 42.0% | 17.0% | |
| 🇲🇹 Malta | Worldwide | 35.0% | 35.0% | 🏷️ |
| 🇹🇼 Taiwan | Worldwide | 40.0% | 20.0% | |
| 🇲🇶 Martinique | Worldwide | 45.0% | 25.0% | |
| 🇬🇵 Guadeloupe | Worldwide | 45.0% | 25.0% | |
| 🇬🇫 French Guiana | Worldwide | 45.0% | 25.0% |
🔗 RELATED
Zero Income Tax
💰 Zero Tax Countries →
Territorial Systems
🌍 Territorial Tax Countries →
Low Rate (1-15%)
📊 Low Rate Countries →
No Capital Gains
📈 No CGT Countries →
Exit Tax
🚪 Exit Tax Countries →
Non-Dom Regimes
🏷️ Non-Dom Regimes →
Crypto Tax
₿ Crypto Tax Countries →
Overview
💎 Low-Tax Overview →
⚠️ DISCLAIMER
CFC rules vary significantly in scope, thresholds, and exemptions. Some apply only to passive income, others to all income of low-taxed entities. EU members implement ATAD directives with local variations. The details shown are summaries — always consult a qualified tax professional for advice on CFC exposure.