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CFC rule countries

59 jurisdictions with Controlled Foreign Corporation anti-avoidance rules

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 (59)

CFC rule countries
Country System PIT CIT VAT CGT CFC details Regime
RU Russia Worldwide 22.0% 25.0% 20.0% 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% 26.8% Foreign Accrual Property Income (FAPI) rules tax Canadian shareholders of CFCs o... —
CN China Worldwide 45.0% 25.0% 13.0% 20.0% — 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% CFC rules apply to Brazilian residents controlling foreign entities. —
AU Australia Worldwide 45.0% 30.0% 10.0% 22.5% CFC rules apply to Australian shareholders with 10%+ interest in foreign compani... —
IN India Worldwide 30.0% 25.2% 18.0% 20.0% — Non-dom
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% 10.0% — —
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% 11.0% 0.1% — —
PE Peru Worldwide 30.0% 29.5% 18.0% 5.0% CFC rules apply to Peruvian residents controlling entities in low-tax jurisdicti... —
ZA South Africa Worldwide 45.0% 27.0% 15.0% 18.0% — —
CO Colombia Worldwide 39.0% 35.0% 19.0% 15.0% CFC rules apply when Colombian residents control foreign entities in low-tax jur... —
NG Nigeria Worldwide 25.0% 30.0% 7.5% 30.0% — —
VE Venezuela Worldwide 34.0% 34.0% 16.0% — CFC rules apply - income from low-tax jurisdiction entities attributed to Venezu... —
TR Turkey Worldwide 40.0% 25.0% 20.0% 0.0% CFC rules for Turkish entities owning >50% in foreign entities with <10% effecti... —
CL Chile Worldwide 40.0% 27.0% 19.0% 10.0% CFC rules tax Chilean residents on passive income from controlled foreign entiti... Non-dom
FR France Worldwide 45.0% 25.0% 20.0% 30.0% 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 effective from 2022 for >50% controlled entities taxed at <13% —
ES Spain Worldwide 47.0% 25.0% 21.0% 28.0% CFC rules apply when >50% held in entity taxed at <75% of equivalent Spanish tax Non-dom
SE Sweden Worldwide 52.0% 20.6% 25.0% 30.0% CFC rules if entity taxed at less than 55% of Swedish rate and is in a listed ju... —
JP Japan Worldwide 45.0% 23.2% 10.0% 20.3% — 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 44.0% 20.0% 25.5% 34.0% CFC rules if >25% held and entity taxed at rate <3/5 of Finnish rate —
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 >50% held and entity taxed at <14.25% (75% of Polish CIT) —
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% CFC rules apply for entities in tax havens. —
NZ New Zealand Worldwide 39.0% 28.0% 15.0% 0.0% — 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% 10.0% CFC rules for holdings >50% in entities taxed below 50% of Romanian rate Nomad
GR Greece Worldwide 44.0% 22.0% 24.0% 15.0% CFC rules for >50% holdings in entities taxed at less than 50% of Greek rate Nomad Non-dom
BG Bulgaria Worldwide 10.0% 10.0% 20.0% 10.0% EU Anti-Tax Avoidance Directive CFC rules implemented —
IS Iceland Worldwide 46.2% 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% — —
HU Hungary Worldwide 15.0% 9.0% 27.0% 15.0% CFC rules for entities with effective tax below 50% of Hungarian CIT (i.e. <4.5%... —
PT Portugal Worldwide 48.0% 21.0% 23.0% 28.0% CFC rules apply to holdings >25% in low-tax jurisdictions (tax rate <50% of Port... Non-dom
RS Serbia Worldwide 10.0% 15.0% 20.0% 15.0% CFC rules for >50% held entities with effective tax <15% —
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% CFC rules for holdings >50% in entities taxed at less than 50% of Lithuanian rat... —
LV Latvia Worldwide 33.0% 20.0% 21.0% 20.0% CFC rules under ATAD implementation —
HR Croatia Worldwide 35.4% 18.0% 25.0% 12.0% CFC rules under ATAD implementation Nomad
SK Slovakia Worldwide 35.0% 21.0% 23.0% 19.0% CFC rules under ATAD implementation —
EE Estonia Worldwide 22.0% 22.0% 24.0% 22.0% CFC rules under ATAD apply to holdings >50% in low-tax entities Nomad
DK Denmark Worldwide 60.5% 22.0% 25.0% 42.0% CFC rules if >50% owned subsidiary taxed at <75% of Danish rate Non-dom
NL Netherlands Worldwide 49.5% 25.8% 21.0% 36.0% CFC rules apply when Dutch entity has >50% interest in foreign entity with effec... Non-dom
BE Belgium Worldwide 50.0% 25.0% 21.0% 0.0% CFC rules (Cayman tax) apply to income of low-taxed foreign structures —
IL Israel Worldwide 50.0% 23.0% 18.0% 25.0% — Non-dom
SI Slovenia Worldwide 50.0% 22.0% 22.0% 25.0% CFC rules under ATAD implementation —
CY Cyprus Worldwide 35.0% 12.5% 19.0% 20.0% CFC rules for >50% holdings in entities taxed at less than 50% of Cyprus rate Nomad Non-dom
LU Luxembourg Worldwide 42.0% 17.0% 17.0% 21.0% CFC rules under ATAD implementation —
MT Malta Worldwide 35.0% 35.0% 18.0% 35.0% CFC rules under ATAD implementation Nomad Non-dom
TW Taiwan Worldwide 40.0% 20.0% 5.0% 0.0% — —
MQ Martinique Worldwide 45.0% 25.0% 8.5% 30.0% French CFC rules apply. —
GP Guadeloupe Worldwide 45.0% 25.0% 8.5% 30.0% French CFC rules apply. —
GF French Guiana Worldwide 45.0% 25.0% — 30.0% French CFC rules apply. —

Related

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.