• Increase in corporate tax rate from 12.5% to 15% for all companies
• Decrease in withholding tax on dividend payments made to associated companies in low-tax jurisdictions from 17% to 5%
• No exemption for profits of foreign permanent establishments (PEs) located in jurisdictions included on the EU list of non-cooperative jurisdictions
• Extension of loss carry-forward period from five years to up to 10 years, subject to certain conditions
• Extension until 2030 of 120% super-deduction for qualifying research and development (R&D) expenditure on intangible assets
• Introduction of 120% super deduction for qualifying expenditure on machinery and installations used for agricultural or livestock production
• Introduction of 8% flat income tax rate on gains arising from cryptoasset transactions

The measures generally are effective January 1, 2026.

Read a January 2026 report prepared by KPMG’s EU Tax Centre

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