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CFC rule countries

69 jurisdictions with Controlled Foreign Corporation anti-avoidance rules

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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.

All CFC rule jurisdictions (69)

CFC rule countries
Country System PIT CIT VAT CGT CFC details Regime
RU Russia Worldwide 22.0% 25.0% 22.0% 15.0% CFC rules for Russian tax residents owning >25% (or >10% if total Russian owners... —
CA Canada Worldwide 33.0% 15.0% 5.0% 27.4% Foreign Accrual Property Income (FAPI) rules tax Canadian shareholders of CFCs o... —
CN China Worldwide 45.0% 25.0% 13.0% 20.0% Individuals controlling enterprises in low-tax jurisdictions may be subject to t... Non-dom
US United States Citizenship based 37.0% 21.0% — 20.0% Subpart F and GILTI rules tax US shareholders on certain CFC income. BEAT applie... —
BR Brazil Worldwide 27.5% 34.0% — 22.5% Brazilian residents controlling foreign entities are subject to CFC rules on pas... —
AU Australia Worldwide 45.0% 30.0% 10.0% 22.5% CFC rules apply to Australian shareholders with 10%+ interest in foreign compani... —
AR Argentina Worldwide 35.0% 35.0% 21.0% 15.0% CFC (transparent tax regime) applies to Argentine residents with control over fo... —
KZ Kazakhstan Worldwide 15.0% 20.0% 16.0% 15.0% Controlled foreign company rules apply when a Kazakhstan resident holds at least... —
MX Mexico Worldwide 35.0% 30.0% 16.0% 10.0% CFC rules apply to Mexican residents with control over foreign entities in prefe... —
ID Indonesia Worldwide 35.0% 22.0% 12.0% 0.1% Indonesian taxpayers with at least 50% direct or indirect ownership of a foreign... —
MN Mongolia Worldwide 20.0% 25.0% 10.0% 10.0% From 2020, a foreign entity is a CFC when a Mongolian resident entity or permane... —
PE Peru Worldwide 30.0% 29.5% 18.0% 5.0% Passive income from controlled foreign companies (50%+ ownership, voting rights... —
ZA South Africa Worldwide 45.0% 27.0% 15.0% 18.0% Residents are taxed on attributable income from controlled foreign companies und... —
CO Colombia Worldwide 39.0% 35.0% 19.0% 15.0% CFC rules apply when Colombian residents control foreign entities in low-tax jur... —
TZ Tanzania Worldwide 30.0% 30.0% 18.0% 10.0% Controlled foreign trust and corporation rules can attribute unallocated income... —
NG Nigeria Worldwide 25.0% 30.0% 7.5% 25.0% Where a foreign company controlled by a Nigerian company does not distribute pro... —
PK Pakistan Worldwide 45.0% 29.0% 18.0% 15.0% Attributable undistributed income of controlled foreign companies may be taxed a... —
MZ Mozambique Worldwide 32.0% 32.0% 16.0% 32.0% Profits of non-resident companies in a clearly more favourable tax regime are at... —
TR Turkey Worldwide 40.0% 25.0% 20.0% 40.0% Turkish controllers (≥50% participation) may be taxed currently on passive low-t... —
CL Chile Worldwide 40.0% 27.0% 19.0% 10.0% Chilean residents are taxed on passive income from controlled foreign entities i... Non-dom
FR France Worldwide 45.0% 25.0% 20.0% 31.4% CFC rules apply to >50% holdings in entities subject to privileged tax regime (<... —
UA Ukraine Worldwide 18.0% 18.0% 20.0% 18.0% CFC rules apply from 2022: Ukrainian residents controlling foreign entities (>50... —
ES Spain Worldwide 47.0% 25.0% 21.0% 30.0% CFC rules apply when >50% held in entity taxed at <75% of equivalent Spanish tax Non-dom
PG Papua New Guinea Worldwide 42.0% 30.0% 10.0% 15.0% Controlled foreign company rules attribute qualifying passive (property) income... —
SE Sweden Worldwide 52.0% 20.6% 25.0% 30.0% Swedish residents taxed on low-taxed foreign companies (generally below 11.33% e... —
UZ Uzbekistan Worldwide 12.0% 15.0% 12.0% 12.0% From 1 January 2022, Uzbek tax residents (individuals and legal entities) contro... —
JP Japan Worldwide 45.0% 23.2% 10.0% 20.3% Japanese parent companies include undistributed profits of foreign related corpo... Non-dom
DE Germany Worldwide 45.0% 15.8% 19.0% 26.4% CFC rules apply when German shareholders hold >50% and entity is subject to low... —
FI Finland Worldwide 37.5% 20.0% 25.5% 34.0% Finnish residents (and Finnish PEs of non-residents) may be taxed on undistribut... —
NO Norway Worldwide 47.4% 22.0% 25.0% 37.8% CFC rules apply when Norwegian taxpayers hold >50% and effective tax rate <2/3 o... —
PL Poland Worldwide 32.0% 19.0% 23.0% 19.0% CFC rules when Polish residents hold more than 50% and foreign entity is taxed b... —
IT Italy Worldwide 43.0% 24.0% 22.0% 26.0% CFC rules apply when effective tax rate is less than 50% of Italian rate Non-dom
EC Ecuador Worldwide 37.0% 25.0% 15.0% 10.0% Ecuador residents with at least 25% participation in a foreign entity taxed belo... —
NZ New Zealand Worldwide 39.0% 28.0% 15.0% 0.0% Controlled foreign company rules attribute passive income from foreign companies... Nomad Non-dom
GB United Kingdom Worldwide 45.0% 25.0% 20.0% 24.0% CFC rules apply to UK-resident companies with >25% interest in low-taxed foreign... —
RO Romania Worldwide 10.0% 16.0% 21.0% 16.0% Controlled foreign company rules apply when a taxpayer (alone or with associated... Nomad
GR Greece Worldwide 44.0% 22.0% 24.0% 15.0% Undistributed income of a >50%-controlled foreign entity is attributed when fore... Nomad Non-dom
BG Bulgaria Worldwide 10.0% 10.0% 20.0% 10.0% EU Anti-Tax Avoidance Directive controlled foreign company rules apply. —
IS Iceland Worldwide 46.3% 20.0% 24.0% 22.0% CFC rules for low-taxed controlled entities. —
KR South Korea Worldwide 45.0% 25.0% 10.0% 20.0% Undistributed earnings of foreign corporations owned at least 10% by Korean resi... —
HU Hungary Worldwide 15.0% 9.0% 27.0% 15.0% A foreign entity or permanent establishment is a controlled foreign company when... —
PT Portugal Worldwide 48.0% 19.0% 23.0% 28.0% CFC rules can attribute income from a foreign entity where the Portuguese taxpay... Non-dom
AT Austria Worldwide 55.0% 23.0% 20.0% 27.5% CFC rules for passive income of >33% in low-tax jurisdictions —
CZ Czech Republic Worldwide 23.0% 21.0% 21.0% 15.0% CFC rules for entities taxed at effective rate less than 50% of Czech rate —
IE Ireland Worldwide 40.0% 12.5% 23.0% 33.0% CFC rules apply to Irish-resident companies with >50% control of CFCs with low-t... Non-dom
LT Lithuania Worldwide 32.0% 17.0% 21.0% 20.0% A foreign entity is a CFC if a Lithuanian company holds more than 50% of voting... —
LV Latvia Worldwide 33.0% 20.0% 21.0% 25.5% CFC rules under ATAD implementation. —
HR Croatia Worldwide 33.0% 18.0% 25.0% 12.0% CFC rules follow EU ATAD implementation for Croatian residents with interests in... Nomad
SK Slovakia Worldwide 35.0% 24.0% 23.0% 19.0% Corporate CFC rules attribute income of low-taxed foreign entities controlled by... —
EE Estonia Worldwide 22.0% 22.0% 24.0% 22.0% CFC rules (§ 54³, ATAD): profits of a foreign entity or PE controlled (>50% vote... Nomad
DK Denmark Worldwide 60.5% 22.0% 25.0% 42.0% Danish CFC rules apply when a Danish company (alone or with associates) controls... Non-dom
NL Netherlands Worldwide 49.5% 25.8% 21.0% 36.0% CFC rules apply when a Dutch taxpayer has a more than 50% interest in a foreign... Non-dom
BE Belgium Worldwide 50.0% 25.0% 21.0% 10.0% CFC rules (Cayman tax) tax certain income of low-taxed or transparent foreign le... —
AL Albania Worldwide 23.0% 15.0% 20.0% 15.0% Residents may be taxed at 15% on passive income from controlled foreign entities... —
IL Israel Worldwide 50.0% 23.0% 18.0% 25.0% Israeli residents controlling foreign companies meeting CFC conditions may be ta... Non-dom
SI Slovenia Worldwide 50.0% 22.0% 22.0% 25.0% A foreign entity is a controlled foreign company when a Slovenian taxpayer alone... —
CY Cyprus Worldwide 35.0% 15.0% 19.0% 20.0% CFC rules apply when Cyprus residents control foreign entities taxed at less tha... Nomad Non-dom
LU Luxembourg Worldwide 42.0% 16.0% 17.0% 22.9% CFC rules under Article 164ter LIR (ATAD): Luxembourg companies and permanent es... —
MU Mauritius Remittance 20.0% 15.0% 15.0% 0.0% Controlled foreign company rules apply from the income year starting 1 July 2020... —
AD Andorra Worldwide 10.0% 10.0% 4.5% 10.0% Article 29 bis imposes a fiscal transparency regime on Andorran residents who co... —
MT Malta Worldwide 35.0% 35.0% 18.0% 35.0% CFC rules apply under EU ATAD implementation. Nomad Non-dom
TW Taiwan Worldwide 40.0% 20.0% 5.0% 0.0% — —
RE Reunion Worldwide 45.0% 25.0% 8.5% 31.4% CFC rules apply to >50% holdings in entities subject to a privileged tax regime... —
MQ Martinique Worldwide 45.0% 25.0% 8.5% 31.4% CFC rules apply to >50% holdings in entities subject to a privileged tax regime... —
GP Guadeloupe Worldwide 45.0% 25.0% 8.5% 31.4% CFC rules apply to >50% holdings in entities subject to a privileged tax regime... —
GI Gibraltar Territorial 39.0% 15.0% — 0.0% Gibraltar companies may be taxed on undistributed profits of controlled foreign... Non-dom
GF French Guiana Worldwide 45.0% 25.0% — 31.4% CFC rules apply to >50% holdings in entities subject to a privileged tax regime... —
YT Mayotte Worldwide 45.0% 25.0% — 31.4% CFC rules apply to >50% holdings in entities subject to a privileged tax regime... —
NF Norfolk Island Worldwide 45.0% 30.0% — 22.5% Australian controlled foreign company rules apply to residents with qualifying i... —
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.
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