Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

Corporations are subject to a minimum corporate income tax of 5 percent of the statutory minimum capital (GmbH and FlexCo since 2024 EUR500 (5 percent of EUR10,000), GmbH until 2023 EUR1,750 (5 percent of EUR35,000), GmbHs founded after 2013 until the end of 2023: reduced to EUR500 in the first 5 years after formation, EUR1.000 for the subsequent 5 years, AG EUR3,500 (5 percent of EUR70,000)). Special provisions apply for banks and insurance companies.

Belgian legislation does not provide for alternative minimum tax.

The Brazilian Government has introduced Pillar 2 rules from OECD, ensuring that entities belonging to multinational groups with annual revenues of at least EUR750 million in 2 of the last 4 fiscal years are subject to a minimum effective tax of 15 percent tax rate – the so-called CSLL Surcharge.

The CSLL Surcharge follows the reference documents approved by the OECD Inclusive Framework, thereby qualifying as a Qualified Domestic Minimum Top-up Tax (QDMTT). So far, Brazil has not introduced the other GlobBE rules, such as Income Inclusion Rule (IIR) and Undertaxed Profits Rules (UTPR).

Corporations (non-resident or resident) are not subject to federal alternative minimum tax in Canada. A corporate minimum tax may be imposed at the provincial level.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

Not applicable.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

Companies are required to pay corporate income tax (based on a so-called minimum taxable base) even if they do not make a profit, unless they present their cost structure on an additional form attached to their tax returns.

Every domestic corporation is subject to Minimum Alternate Tax (MAT) of 15 percent for assessment year 2025–­26 (financial year 2024–25). A corporation pays the greater of its regular tax liability and its MAT tax liability. Foreign corporations may also be subject to MAT. However, companies opting to pay a concessional tax rate of 22 percent or 15 percent, as the case may be, are not required to pay MAT. Every non-corporate taxpayer also is required to pay Alternate Minimum Tax (AMT) of 18.5 percent.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

Non-operating companies are subject to a minimum level tax, depending on the assets they own.

Under Japanese tax law, there are no taxes that are equivalent to the Alternative Minimum Tax. The Qualified Domestic Minimum Top-up Tax (QDMTT) is being legislated and is expected to be effective from April 2026.

Not applicable for this jurisdiction. However, please see the developments on minimum wealth tax discussed below.

Not applicable.

Simplified tax for small taxpayers (ISPC)

The ISPC is a direct tax applicable to natural or legal persons engaged in small-scale agricultural, industrial or commercial activities, including the provision of services, in the national territory. For the purposes of this tax, a small-scale business is one the annual turnover of which is less than or equal to MZN2.5 million (approximately USD 39,513.20 at the exchange rate of USD1 = MZN 63.27).

Taxpayers who opt for ISPC on their activities of supply of goods and services are no longer subject to VAT, and any income derived from those activities will not be subject to either personal income tax (IRPS) or corporate income tax (IRPC).

ISPC is due for each tax year, which coincides with the calendar year. Applicable rates are as follows: Annual rate of ISPC MZN75,000 (approx. USD 1,185.40 at the exchange rate of USD1 = MZN 63.27). Alternatively, a 3 percent rate on the turnover may be applied.

For taxpayers who commence business and opt for the 1st time for the ISPC a reduction of 50 percent of the applicable tax rate in the 1 year of activity is available.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

In Poland, legislation establishing a minimum corporate tax went into effect in 2022. This tax, however, will apply to tax years beginning after December 31, 2023.

Minimum corporate tax will be levied on any entity subject to CIT (including tax capital groups) that:

• suffered a loss for a given tax year or
• whose share of income in revenues (other than capital gains) calculated for tax purposes is less than 2 percent.

The provision will not apply, inter alia, to startups or taxpayers who recorded over a 30-percent decrease in revenues.

Not applicable for this jurisdiction.

Micro-companies tax

Romanian legal entities that register a cumulative level of their taxable revenues (as listed by the tax legislation) lower than the RON equivalent of EUR1 million in the previous year are subject to a specific micro-companies taxation system. Micro-companies are liable to pay a tax on their turnover of 1 percent for companies having at least one employee on their payroll and 3 percent otherwise.

Entities that operate in the hospitality industry are obliged to apply a specific taxation regime that is based on business capacity and not on the level of the profits derived from their activity.

Casinos are obligated to apply the corporate income tax regime and pay a tax no lower than 5 percent of revenues related to gambling activities.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

However, Singapore has implemented the Global Anti-Base Erosion (GloBE) Rules as part of OECD’s Pillar Two framework, effective from January 1, 2025. The key components include:

• A Domestic Top-up Tax (DTT) will be applied to in-scope MNE groups in respect of any low-taxed profits of their group entities that are operating in Singapore, to ensure an effective tax rate of at least 15 percent for the Singaporean constituent entities of the group.
• An Income Inclusion Rule (IIR), referred to as Multinational Enterprise Top-up Tax (MTT), will be applied to in-scope MNE groups that are parented in Singapore, in respect of any low-taxed profits of their group entities that are operating outside Singapore, to also ensure an effective tax rate of at least 15 percent for the MNE group’s overseas constituent entities.

The implementation of the Undertaxed Profits Rule (UTPR) will be considered at a later stage.

Not applicable for this jurisdiction.

Every domestic corporation is subject to minimum tax. A corporation pays the greater of its regular tax liabilities or its minimum tax liability. Foreign corporations are subject to minimum tax on taxable income that is effectively connected with domestic source income.

Taxpayers with net turnover exceeding a EUR20 million threshold, or those taxed under a consolidated basis, will be taxed using, in general, a minimum tax quota of 15 percent of the taxable base.

Not applicable for this jurisdiction.

In half of the cantons, instead of corporate income tax, a minimum tax is paid, provided such minimum tax exceeds the corporate income tax otherwise due. There are no minimum taxes on a federal level.

According to the Taiwan Income Basic Tax Act, a domestic company or a foreign company with a fixed place of business/permanent establishment or business agent in Taiwan (PE) is subject to a separate alternative minimum tax (AMT) if it earns certain income that is tax exempt or enjoys certain tax incentives and the company’s basic income exceeds TWD600,000. The AMT rate is 12 percent. If the company’s regular income tax is greater than the AMT, no special action is required. If the AMT tax liability is greater than the regular income tax, the company is required to calculate and pay AMT.

As of January 1, 2025, a 10 percent mandatory domestic minimum corporate tax regime is introduced. This minimum tax is calculated on taxable income before applying certain exemptions or deductions. Accordingly, corporations will be required to pay the higher of the two amounts: either the standard corporate income tax or the domestic minimum corporate tax.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

Not applicable for this jurisdiction.

The corporate alternative minimum tax is repealed for tax years beginning after 2017.

Presumptive tax is payable as an alternative to normal corporate tax but this option is only available to informal traders and certain categories of self-employed professionals. It is expressed as a fixed sum for each category of informal trader or self-employed professional.