CountryMINIMUM SHARE CAPITALLOCAL DIRECTORS REQUIREDTIME TO FORMCOST TO FORMCORPORATION TAX RATE ON DIVIDENDS RECEIVEDCREDIT FOR FOREIGN CORPORATION TAX/WITH-HOLDING TAXWITHHOLDING TAX RATE ON DIVIDENDS PAIDCAPITAL GAINS TAX RATE ON SALE OF SUBSIDIARIESAUDIT REQUIREMENT
BulgariaApprox. € 25,000 for Joint Stock Company (abbreviated as AD) and € 2,500 for limited liability company (abbreviated as OOD) No1-2 weeksBetween € 150 and € 1,000 (for Trade register, translation and notary fees) + lawyer’s fees in additionNil for dividends received from another BG or EU company ( they are not a taxable income)Generally yes to both depending on relevant DTA Nil10% corporate income tax on the difference between acquisition and sale valueIf two out of the following size criteria have been exceed for two consecutive years: balance – sheet total, turnover, employees.
Colombia1 share of 1 Pesos. No2 weeks approx.Depends on the capitalMaximum 33%, but can be 0% dependent on how much the company receivesGenerally yes to both depending on relevant DTA33%33%Depends on size of company and/or group.
Cyprus1 share of any currency Not obligatory under the law. However advisable for a number of reasonsOne or two weeksCompetitive in the European MarketNilGenerally yes, credit is allowed and withholding tax deductible. Both above dependant on relevant DTA.Nil to non residents, individuals and corporations NilStatutory Audit under ISAs for Companies. Consolidated Audited Financial Statements dependant on size of group.
 EgyptLE $ 50,000; Equ $10,000 NoOne month$ 5,000NilNo Nil 12% 
 France€ 1 for SARL and SAS: Variable Stated capital for partnerships; € 37,000 for SA No, but decision should be taken in FranceFew days to several weeksApprox. € 100 + € 300 for publication + if requested lawyer (e.g. for individual articles of association)Normally 5%Generally yes to both depending on relevant DTANo withholding tax in France on dividends paid by a French holding company to its top EEC holding companyNo capital gains tax on sale of shares of subsidiaries if various conditions are fulfilled: (i) real estate companies not listed or listed on stock exchange do not benefit from exemption; (ii) Parent company holds 5% and more of the capital of its subsidiary; (iii) Shares are held for two years at least; (iv) Taxation upon 5% of the net profit of the sale of shares of subsidiariesDepends on nature of the company and/or on balance sheet, turnover and number of employees criteria. Statutory Auditor required for SA and for SAS held by (or holding) other company.

CountryMINIMUM SHARE CAPITALLOCAL DIRECTORS REQUIRED?TIME TO FORMCOST TO FORMCORPORATION TAX RATE ON DIVIDENDS RECEIVEDCREDIT FOR FOREIGN CORPORATION TAX/WITHHOLDING TAXWITHHOLDING TAX RATE ON DIVIDENDS PAIDCAPITAL GAINS TAX RATE ON SALE OF SUBSIDIARIESAUDIT REQUIREMENT
Germany1 for UG (haftungsbeschränkt) and € 25,000 for GmbH (=Ltd.)No, but decision should be taken in Germany1 week to several weeksApprox. € 500 (for notary and court) + if requested lawyer (e.g. for individual articles of association or tax consultant for fiscal registration)Normally 5%Generally yes to both depending on DTA Normally 5%If two out of the following size criteria have been exceed for two consequtive years: balance-sheet total, turnover, employees
Hungary€ 1,667 (HUF 500,000) for Limited Liability Company and € 16,667 (HUF 5,000,000) for Privately held shared company.NoNormal: 15 days, Simplified: 1 working hourDuties: € 350 in case of normal procedure + lawyers’ costs, € 50 + lawyer if needed in case of simplified procedureNormally 5% - 15%Generally yes to both depending on relevant DTA. No tax credit if dividends are paid by CFC  Yes, but only if 2 out of 3 criteria are met: 1) assets > € 4.4 M; 2) turnover > € 8.8 M; 3) 50 or more employees
IndiaRs 100,000 for private limited and Rs 500,00 for public limitedNo2 weeks from formastion with foreign shareholders / directorsApprox. Rs. 100,000Maximum 33.99%Generally yes to both depending on relevant DTAa) Dividend to a resident – deemed dividend u/s (22) (e) – max 22.66%. Any other dividend – nil. b) Dividend to a non resident. Where no DTA exists – max of 42.23%. Where DTA exists – as per the rate prescribed therein Mandatory for all companies
Isle of Man£ 2No. However a local Registered Office is requiredSame day, or if you require a specific name say, one weekApprox. £ 600 plus VATZeroNot applicableZeroThere is no Capital Gains Tax in the Isle of ManThere is no statutory requirement for Audit if the articles so provide. However an audit will be required if the company exceeds two of the following criteria, its turnover is in excess of £ 5.6 Million, its net assets are more than £ 2.8 Million and or its employees exceed 50

 

 


CountryMINIMUM SHARE CAPITALLOCAL DIRECTORS REQUIRED?TIME TO FORMCOST TO FORMCORPORATION TAX RATE ON DIVIDENDS RECEIVEDCREDIT FOR FOREIGN CORPORATION TAX/WITHHOLDING TAXWITHHOLDING TAX RATE ON DIVIDENDS PAIDCAPITAL GAINS TAX RATE ON SALE OF SUBSIDIARIESAUDIT REQUIREMENT
Italy€ 120,000 for SpA (=Corporation) and € 10,000 for Srl (=limited)NoSame day. Registration needs up to 3 weeks. Business may be done.Approx € 5,000 for SpA and € 3,000 for Srl (notary and register) + 1% tax on registered capital.Normally 27.5%  on 5% of amount (ie 1,375%)Generally yes to both depending on relevant DTADepending on relevant DTA. Normal rate 12.5% not always dueNormally 27.5%. May be 5% of normal rate provided certain conditions are met.Yes for SpA
Depending on size for Srl
Jersey£ 1NoSame day once due diligence completed£ 2,000ZeroZeroZeroZeroNone
Luxembourg€ 12,500 for Sarl, € 31,000 for S.A.No but substance required in Luxembourg2-3 weeksApprox € 3,000 for Sarl, € 4,500 for a S.A (all costs included)0% if conditions of the EU parent/subsidiary directive are met. Outside EU depending on relevant DTAGenerally yes to both depending on relevant DTANormal rate is 15% but may be nil if conditions of the EU parent/subsidiary directive are met. Outside EU depending on relevant DTA0% if certain conditions are met (at least 10%) shareholding or € 6 million for at least 12 monthsDepends on size of company
Malta€ 1,165No but Malta substance is recommended1 week from submission of documentsBetwwen € 3,000 to € 5,000 depending on complexity0% if the EU parent/subsidiary directive is applied. Outside EU it depend on relevant DTANoNil35%We hereby confirm that Malta Companies are subject to an annual audit as per Companies Act mandatory rules
MauritiusAny value no par value shares1 for domestic companies. 2 for global licence 1 companies (offshore) Non for global licence 2 companies (international co)3 days for domestic. 2-3 weeks for GBL1 and GBL2.Domestic co € 500; GBL1: € 6,000; GBL2: € 2,000Dividends from Mauritius companies exempt. Dividends from foreign companies 15%  (with 80% automatic tax credit) for GBL1; GBL2 exemptDomestic company – 100%. GBL1 – 100% or 80% automatic tax credit whichever more favourable. GBL2 – exemptNoneNoneDomestic small private company (turnover < € 700,000) – None. Others – audit required. GBL2 - None
MexicoUS$ 3,900 (50,000 Mexican pesos)No, could be a foreign personOne weekUS$ 650 for notary fees + lawyer fees in case of special clauses + tax consultant for fiscal registrationNot taxable if the dividend is paid by a Mexican Entity. Otherwise 30% rateIf the dividend comes from other country the Mexican entity could credit the tax withheldThere is no withholding tax if the profits related were not taxedThe tax rate is at 30% in case of gain. If the entity is considered public or participates in the stock market there is no withholding taxYes

 

 


CountryMINIMUM SHARE CAPITALLOCAL DIRECTORS REQUIRED?TIME TO FORMCOST TO FORMCORPORATION TAX RATE ON DIVIDENDS RECEIVEDCREDIT FOR FOREIGN CORPORATION TAX/WITHHOLDING TAXWITHHOLDING TAX RATE ON DIVIDENDS PAIDCAPITAL GAINS TAX RATE ON SALE OF SUBSIDIARIESAUDIT REQUIREMENT
 NetherlandsEuropean Company (SE): € 120,000. Public limited company (NV): € 45,000. Private limited company (BV): € 18,000; Cooperative (Co-op): no minimum capital requirements. Open limited partnership (CV): No minimum capital requirements.Company Law perspective: No local directors required. Tax perspective: (i) For certain tax rulings 50% of the directors should be residents of the Netherlands; (ii) Board Meetings should be held in the Netherlands to avoid dual residence of the companyIncorporation can be done in 2 to 3 weeks if all paperwork is done properly. A notary public has to be involved in the incorporation.Co-op: € 3,000 – € 4,000
BV: € 1,500 - € 2,500
NV: € 3,000 - € 4,000
SE: € 5,000 - € 7,000
Under the participation exemption regime, dividends and capital gains received from qualifying shareholdings in domestic and foreign (EU and non-EU) subsidiaries are tax exempt at the level of the Dutch holding company (Co-op, BV, NV, SE). Interest received on a Profit Participating Loan (even if granted to an affiliate other than the directly held subsidiary) is also tax exempt under the participation exemption regimeNo credit for foreign WHT on exempt dividend income under the participation exemption regime. Credit for foreign WHT on dividends if the participation exemption regime does not apply (e.g. a portfolio shareholding). EU subsidiary: If participation exemption does not apply: credit for underlying corporate income tax available in specific circumstancesIn general, a 15% dividend WHT rate applies to dividends paid. However, a Co-op is exempt from dividend WHT. The Netherlands has an extensive tax treaty network (over 80 DTAs). Some DTAs provide for a 0% WHT (e.g. USA, Switzerland). Within the EU, also 0% WHT under the parent-subsidiary directive to qualifying EU parent companies.Under the participation exemption regime, capital gains realized on qualifying shareholdings in domestic and foreign subsidiaries are tax exempt at the level of the Dutch holding company.Yes, but only if 2 out of 3 criteria are met: 1) assets > € 4.4 M. 2) turnover > € 8.8 M. 3) 50 or more emDepends on size of companyployees.
 PolandPLN 5,000 (approx. € 1,190) for Sp. z o.o. (Ltd.) and PLN 100,000 (approx. € 23,800) for joint stock CompanyNo2 – 3 weeksApprox. € 2,500 for Sp. z o.o. and approx. € 3,500 for JSC. All costs included: legal fees, notary, court, publication in court gazetteExempt according to the Parent-Subsidiary Directive, unless the conditions are not met. The same applies to local (Polish) companiesDepending on relevant DTAExempt according to Parent-Subsidiary Directive, unless the conditions are not met. Outside EU depending on relevant DTA. The DTA network is extensive (over 70 countries covered)Generally 19%Depends on size of company
 Slovenia€ 7,500.00 for LLC; € 50,000.00 for Joint-stock CompanyNo1 day for LLC. It depends on type of incorporation procedure of joint-stock company Approx. € 3,000 (lawyer, notary and register)20%, lower depending on DTA, but if the payer of the dividends is an SLO resident company or an EU resident company, dividends are exempt from taxation in the recipient’s handsGenerally yes to both depending on relevant DTA15% or lower depends on DTA20%. Only 50% of the profit is taxed if certain conditions are fulfilledDepends on the size of the company

CountryMINIMUM SHARE CAPITALLOCAL DIRECTORS REQUIRED?TIME TO FORMCOST TO FORMCORPORATION TAX RATE ON DIVIDENDS RECEIVEDCREDIT FOR FOREIGN CORPORATION TAX/WITHHOLDING TAXWITHHOLDING TAX RATE ON DIVIDENDS PAIDCAPITAL GAINS TAX RATE ON SALE OF SUBSIDIARIESAUDIT REQUIREMENT
Spain€ 3,005.06 (sociedad limitadat) and € 60,101.21 (sociedad anonima)NoSame day registration needs one 1 or 2 months but the company may initiate business. Alternatively total time can be reduced to 48 hours (circe)Approx. € 3,000 (lawyer, notary and register) = 1% tax on registered capitalNormal rate is 30%, Small-med sized companies 5% allowance on first € 120,202.42 profit being the tax rate 25%Generally yes to both depending on relevant DTA. No tax credit if dividends are paid by a company resident in a tax heavenNormal rate is 18% but may be less depending on relevant DTA. Nil between EU parent-subsidiary companies (except tax heavens)Normally 30% (5% allowance) may be nil provided certain conditions are met (entidad de tenecia de valores extrajeros).Depends on size of company
SwitzerlandCHF 20,000 for LLC; CHF 100,000 nominal for Ltd. (min. CHF 50,000 paid up)No (but if only foreign directors: a Swiss or EU citizen residing in Switzerland must have right to represent the company)Approx. 1 to 2 weeksApprox. € 4,000 (all in)Cantonal: totally exempt; Federal: participation exemptionNil35% (if no DTA existing); EU-holding 0%Same as dividend received; additionally 1 year holding period and min. 20% resp. CHF 2 Mio participation (reduction to 10% and CHF 1 Mio imminent)Depends on size of company and/or group
United Kingdom1 share of any currencyNoSame day once due diligence completed.MinimalNil provided certain conditions are met. For small companies the payer should be based in a country which has a relevant DTA with the UKGenerally yes to both depending on relevant DTA and size of holding unless UK corporation tax is nilNilNil provided certain conditions are met (Substantial Shareholdings Exemption)Depends on size of company and/or group
USA

There is no national law regulating corporations. Each state and the District of Columbia has its unique statue controlling corporate governance issues. Typically Delaware is the jurisdiction of choice because it has a well established body of law in relation to corporate governance issues and a well respected court system.
NoneNoneImmediateUnder $ 1,000, exclusive of professional fees and disbursements 34% / 35% 2, subject generally to a dividend received deduction of (i) 100% for dividends paid by 80% + subsidiaries, (ii) 80% for dividends paid by corporations in which the recipient owns at least 20% but less than 80% of the dividend paying company, and (iii) 70% for dividends paid by corporations in which the recipient owns less than 20% of the shares. 3 dividends received from a non-US corporation are fully taxed unless the foreign corporation is engaged in a US trade or business and the earnings from which the dividends are paid were generated from that business.
1) The maximum corporate tax rate is 35% for taxable profits over $ 10 million.
2) Excludes potential state taxes. However most states exclude dividends
Yes/yes. States typically do not allow a foreign tax credit for foreign taxes paid on dividends paid by non-US Corporations or foreign corporate taxes paid on earnings from which the dividend is paid. One exception is New York State.30% in the absence of an applicable treaty34% / 35%None unless the company has registered shares that are publicly traded or the company engages in a business that is regulated by a State or Federal government body
Venezuela€ 7,00 (sociedad responsabilidad limitada). € 1,00 (sociedad anónima). Registrar may establish minimum capital according to the kind of activity of the company. More than € 700 recommendedNo but it is recommended2 weeks to several weeksDepends on capital. Approx € 1,750 including legal expenses, 1% tax on registered capital of € 700Normal rate is 34%Generally yes to both depending on relevant DTA.Normal rate is 34% (special rules apply)Depends on the size of company e.g. insurance companies, banks, public companies etc.Depends on size of company and kind of company (e.g. insurance companies, Banks, public companies, etc.).

 

 


Whilst every effort has been made to ensure accuracy, information and data contained in this schedule may not be up-to-date or comprehensive enough. Recipients and/or readers are therefore advised to seek professional guidance and formal advice and should not act or advise their clients purely on the basis of the information contained herein