In 2025, according to estimates by the European Commission, the average tax burden on businesses across the EU will remain at 21–23%. However, the difference between countries exceeds a threefold gap. While some jurisdictions are tightening control and introducing new requirements for substance and tax transparency, others continue to offer attractive conditions for international companies and investors. According to KPMG and PwC, more than 60% of entrepreneurs planning international expansion are considering registering their business in European countries with low taxes — and this trend is only growing stronger.
Today, I want to share a practical guide based on the experience of COREDO, which will help entrepreneurs and executives choose the optimal jurisdiction, minimize tax risks, and implement an international tax planning strategy. If you are looking not just for a list of low-tax countries, but for an in-depth analysis that considers the nuances of substance, compliance, and long-term consequences for business — I recommend reading this article to the end.
Countries with low taxes for business
COREDO’s experience confirms: registering a business in the EU with low taxes provides not only direct savings but also strategic advantages for scaling and entering new markets. Key benefits include:
- Tax optimization in Europe: Reducing the effective tax rate allows companies to reinvest more funds into growth, R&D, and marketing.
- Tax advantages for entrepreneurs: In a number of countries, tax holidays, investor benefits, and incentives for startups and IT companies are available, significantly lowering entry barriers.
- Flexible tax regimes for foreign companies: Many jurisdictions offer special statuses for tax residents and non-residents, allowing optimization of international capital flows.
- Access to investment programs: Some low-tax European countries offer investment programs for entrepreneurs, simplifying the process of obtaining residence permits and citizenship.
- Tax incentives for startups: COREDO’s program for supporting technology companies has shown that preferential regimes allow businesses to scale quickly without excessive tax burdens.
Thus, registering a business in low-tax countries is not only a matter of direct savings but also of effective company positioning in the global market. Next, let’s look at the requirements for substance, AML compliance, and tax transparency.
Substance requirements, AML, and tax transparency
However, the choice of jurisdiction with minimal taxes for business is always linked to a number of challenges. International standards (OECD, FATF, EU) are tightening requirements for substance — the real economic presence of a company in its country of registration. Insufficient compliance with these requirements may lead to the loss of tax benefits, additional assessments, and even removal of the company from the register.
- Substance requirements: The need for offices, employees, and management decisions within the country. COREDO’s practice shows that many clients underestimate these requirements, leading to tax disputes.
- Compliance (AML/KYC): Stricter monitoring of beneficiaries, automatic tax information exchange (CRS), and mandatory transparent ownership structures.
- Tax transparency: Low-tax countries are increasingly integrating into the European system of automatic data exchange, which requires impeccable compliance and reporting.
- Tax risks and minimization: It is not enough to simply register a company; it is important to build a structure resilient to tax audits and inspections.
Solutions developed by COREDO allow not only the selection of an optimal jurisdiction but also ensuring compliance with all current substance and compliance requirements, minimizing long-term risks.
Therefore, when choosing a country for business registration, it is important not only to consider tax rates but also to analyze in advance the current conditions for meeting substance and compliance requirements.
European countries with low taxes for business 2025
Based on an analysis of legislation, practical application of tax regimes, and client feedback, the COREDO team highlights five European countries with the lowest business taxes in 2025. For each, we will review corporate taxation features, substance requirements, compliance rules, and additional incentives.
Corporate income tax in Bulgaria for companies
Bulgaria consistently ranks among the top European countries with minimal corporate tax. The corporate income tax rate for companies is 10%, with additional incentives for small enterprises. Key features:
- Simple company registration in the EU with minimal taxation: the process takes 1–2 weeks, with a symbolic minimum share capital.
- Tax treaties and double taxation agreements in the EU: more than 70 agreements, including with Asian and CIS countries, helping to avoid double taxation.
- Tax incentives in Europe: special regimes and reduced social contribution rates for IT companies and startups.
- Substance requirements: moderate, sufficient to have an office and a local director.
- Compliance: EU standard, automatic information exchange, transparent reporting.
COREDO’s practice has shown that Bulgaria is an optimal choice for companies targeting the EU and CIS markets, where simplicity of doing business and predictable taxation are priorities.
Minimum corporate tax in Hungary — 9%
Hungary offers the lowest corporate tax rate in the EU — 9%. This is a flat tax applied to all types of business activity. Key features:
- Tax incentives for startups: innovation support programs, grants, and accelerated licensing procedures.
- Benefits for IT companies: reduced rates on intellectual property and accelerated depreciation.
- Corporate tax for foreign investors: no separate registration required for non-residents, remote submission of documents is possible.
- Substance requirements: moderate, but since 2024 there has been increased focus on real presence.
- Compliance: EU standard, with a high level of automated reporting.
The COREDO team has implemented several projects for technology companies where the Hungarian jurisdiction made it possible to reduce the tax burden and simplify compliance procedures.
Business taxes in Montenegro — 9%
Montenegro, while not an EU member, maintains one of the most flexible tax systems in Europe. The corporate tax rate ranges from 9% to 15%, depending on profit levels. Key features:
- Benefits for expats and investment programs for entrepreneurs: simplified residence permits and tax holidays for new companies.
- Tax incentives for attracting capital: special regimes for startups, minimal substance requirements.
- Substance requirements: low — a legal address and a nominee director are sufficient.
- Compliance: moderate, although from 2025 stricter monitoring of beneficiaries is planned.
A COREDO case study for a fintech startup showed that registering a business in Montenegro enables rapid entry into the European market with minimal compliance and maintenance costs.
Corporate tax in Andorra 2025: 10%
Andorra is a unique jurisdiction with one of the lowest effective rates for holding structures in Europe. Key features:
- Corporate tax 10%, for holdings as low as 2% — provided substance requirements are met.
- Tax regimes for holding structures: attractive to international investors, with minimal dividend taxation.
- Tax privileges for investors: opportunity to obtain residency permits, benefits for new companies.
- Substance requirements: high — a full-fledged office, employees, and managerial control are necessary.
- Compliance: strict, especially for financial and investment companies.
A solution developed by COREDO for an international group reduced the effective tax rate to 2% while fully meeting substance and transparency requirements.
Tax benefits for business in Malta
Malta is a leader in the number of double taxation treaties and has a unique tax refund system. Key features:
- Nominal corporate tax rate — 35%, but effective rate 5–10% thanks to the refund system for foreign shareholders.
- Regimes for holding structures: exemption from tax on dividends and capital gains under certain conditions.
- Business tax benefits: startup support programs and tax holidays for new companies.
- Substance requirements: high — a real office, local director, and employees are required.
- Compliance: EU standard, transparent reporting, and regular audits.
COREDO’s practice confirms that for international holding structures and companies working with intellectual property, Malta remains one of the most advantageous and predictable jurisdictions.
Comparative table of tax rates and business conditions in 2025
Country | Corporate Tax | Personal Income Tax | VAT | Business Features | Substance Requirements | AML/Compliance |
---|---|---|---|---|---|---|
Bulgaria | 10% | 10% | 20% | Simple registration, investor benefits | Moderate | EU standard |
Hungary | 9% | 15% | 27% | Startup incentives, flat tax | Moderate | EU standard |
Montenegro | 9% | 9–15% | 21% | Expat benefits, investment programs | Low | Moderate |
Andorra | 10% (2%) | 10% | 4.5% | Minimal burden, residency status | High | Strict |
Malta | 35% (effective 5–10%) | 0–35% | 18% | Tax refund system, holdings | High | EU standard |
Tax benefits for businesses in low-tax countries
Tax incentives for IT companies, startups, and investors
In 2025, tax incentives for startups and IT companies are becoming a key factor when choosing a jurisdiction for registering a low-tax business in the EU. For example, Hungary offers a flat corporate tax program, and innovative companies can access grants and subsidies. In Malta and Bulgaria, tax holidays and reduced rates for new enterprises help minimize the tax burden on small and medium-sized businesses.
COREDO’s practice shows that for technology companies, tax incentives for IT firms, accelerated depreciation opportunities, and exemptions from capital gains tax are particularly important. In Montenegro and Andorra, investment programs for entrepreneurs and favorable tax conditions for expats make these countries attractive to international investors.
Specifics of dividend and profit taxation for foreign owners
The effective tax rate for international companies depends not only on corporate tax but also on the taxation of dividends. In Andorra and Malta, dividend tax for foreign shareholders can be reduced to 0–5%, provided substance requirements are met and double taxation treaties are in place. In Bulgaria and Hungary, the rate on dividends for non-residents is 5–10%, while in Montenegro it is 9%.
The COREDO team recommends that when structuring holding companies in the EU, one should consider not only nominal rates but also the tax implications for international investments, as well as the availability of double taxation treaties.
Business registration and tax residency in the EU
Substance requirements and economic presence
In 2025, substance requirements are becoming increasingly strict. To obtain tax benefits and resident status in the EU, it is important to ensure real economic presence: an office, employees, and managerial decisions made within the country. Failure to meet these conditions may result in the loss of tax advantages and additional assessments.
- Documentary proof of substance: office lease agreements, employment contracts, and local managerial control.
- Compliance (AML/KYC): a transparent ownership structure, disclosure of beneficiaries, and regular reporting.
- Tax transparency: readiness for automatic exchange of tax information (CRS).
Company registration procedure, account opening, and compliance
Company registration in Europe for tax optimization purposes requires strict adherence to procedures:
- Preparation of documents: charter, information on directors and shareholders, address confirmation.
- Application submission to the register: in most countries this is done online; registration takes 3 to 10 business days.
- Opening a bank account: substance confirmation is required, sometimes the director’s personal presence.
- Support and compliance: costs for support and compliance in low-tax countries are usually lower than in “expensive” jurisdictions. At the same time, it is important to consider expenses for audits and tax reporting in the EU.
COREDO’s projects in Bulgaria, Hungary, and Malta show that well-structured corporate frameworks in the EU allow minimizing tax risks and ensuring long-term business sustainability.
Tax risks and trends for business in Europe 2025
How tax regimes and rates are changing in Europe: should we expect tightening?
In 2025, EU tax reforms are aimed at increasing transparency, combating tax evasion, and harmonizing tax infrastructure. Expected developments include:
- Stricter substance requirements: more countries are introducing mandatory real offices and employees.
- Increased tax burden on small and medium-sized businesses: in some countries, higher social contributions and a minimum corporate tax are under discussion.
- Tougher compliance: stronger monitoring of beneficiaries, automatic tax information exchange (CRS), regular inspections, and audits.
COREDO’s recommendation: when choosing a jurisdiction, focus not only on current rates but also on expected legislative changes to avoid unforeseen costs and risks in the future.
Long-term risks of choosing a low-tax jurisdiction
Choosing a country with minimal corporate tax for an international company always involves certain long-term risks:
- Risk of tax rate changes: in 2025, several countries have already announced reviews of preferential regimes.
- Stricter control over substance and compliance: insufficient adherence to requirements may lead to loss of tax residency and additional assessments.
- Reputational risks: using “aggressive” schemes may negatively affect access to banking services and investments.
COREDO’s solutions help minimize these risks through a comprehensive approach: thorough legislative analysis, building transparent structures, and continuous monitoring of changes.
Practical recommendations for business
Practical steps for choosing a low-tax country for business
Based on COREDO’s many years of experience in international tax planning, the following algorithm is recommended:
- Define your strategic business goals: scale, industry, client geography.
- Compare effective tax rates and incentives: do not limit yourself to nominal rates; consider dividend tax, double taxation treaties, and tax holidays.
- Assess substance and compliance requirements: check if you can ensure real presence and transparent ownership structure.
- Calculate ROI and support costs: include expenses for registration, audits, compliance, and account maintenance.
- Check tax risks and long-term trends: study planned tax reforms in the chosen country.
- Prepare the registration document package: charter, beneficiary details, address confirmation, business plan.
- Consult COREDO experts: this will help avoid mistakes at the registration stage and build a sustainable corporate structure in the EU.
COREDO’s practice confirms: only a comprehensive approach to choosing a jurisdiction — considering all aspects, from tax rates to compliance and substance requirements — ensures not only a minimal tax burden but also long-term business sustainability and transparency.
Choosing a low-tax country in Europe in 2025 is not just about finding the lowest rate, but a strategic decision that affects competitiveness, investment attractiveness, and corporate resilience. The COREDO team is ready to be your reliable partner at every stage of this journey, offering solutions based on deep market knowledge, international standards, and real case studies.