No, except for withholding tax on profit remittances/distributions.
Not until the net profits are repatriated. Business profits are first subject to trade tax levied at rates established locally, but generally amounting to 16-20% of profits. The balance is then subject to corporation tax at a flat rate of 26.5% (to fall again to 25% in 2004). A surcharge, the so-called "solidarity levy", of 5.5% is levied on the total corporation tax due. If the trade tax rate is exactly 20%, the overall burden of the three taxes together is thus 42.4%, assuming there to be no variances in the bases of assessment.
A branch, "permanent establishment" in tax terminology, may freely remit its income after tax to its foreign owner or head office. There is no form of "branch tax" or other levy on remitted profits. A subsidiary, on the other hand, remits profits by way of dividend and dividends are subject to withholding taxes depending upon the legal form and country of residence of the shareholder. The standard, unrelieved domestic rate is 20%, but this is reduced under most double tax treaties on dividends paid to corporate shareholders with holdings of more than 25%. The reduced rates for dividends to the USA, for example, are 5% - treaties with other countries foresee a reduced rate of 15%. Inter-corporate dividends within the EU or to Switzerland usually qualify for exemption from withholding tax altogether under the provisions of the EU Parent-Subsidiary Directive.
The content of this article does not constitute legal advice and should not be relied on in that way. Specific advice should be sought about your specific circumstances.
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