法人・個人の課税範囲
Income tax scope

Singapore-source income is taxable. Foreign-source income is generally taxable when received in Singapore (including remittance/bringing into Singapore, use to settle Singapore business debts, or use to acquire movable property brought into Singapore). Foreign income arising from a trade or business carried on in Singapore is taxable on accrual. Specified foreign dividends, branch profits and service income may be exempt subject to foreign-tax, headline-rate (at least 15%) and benefit conditions.

Company residence is not inferred from incorporation/nationality alone; the reviewed scope pages describe the income rules, not a complete company-residence test.

• Complete current company tax-residence test and treaty tie-breakers not reviewed.

Singapore-source income is taxable. Foreign-source income received by a resident individual is generally exempt, except income received through a Singapore partnership. Exceptions include overseas work incidental to Singapore employment and foreign business income incidental to a Singapore trade. Residence is determined by residence/status and day-count rules, not nationality alone (including a general 183-day prior-calendar-year test for foreigners).

IRAS states citizen/PR and foreign individual residence tests; classification concerns resident individual's scope.

• Detailed residence concessions and employment sourcing edge cases not exhaustively reviewed.

A Chinese-resident enterprise is subject to enterprise income tax on income sourced both within and outside China. Residence includes an enterprise established under Chinese law and an enterprise established under foreign law whose effective management is in China; incorporation/nationality alone is not determinative. Nonresident enterprises are generally taxed on specified China-source income and income effectively connected with a China establishment.

EIT Law Article 2 expressly includes effective management in China for foreign-law entities.

• Specific foreign-income exemptions, foreign tax credit limits and treaty interactions not surveyed.

Resident individuals are taxable on income from within and outside China. Residence means domicile in China (habitual residence due to household registration, family or economic interests), or—without domicile—at least 183 days in a tax year. For a non-domiciled individual, foreign-source income paid by an overseas payer is exempt upon filing during the first fewer than six consecutive qualifying years; worldwide taxation applies when the current year and each of the preceding six years meets the 183-day test with no single departure over 30 days. Nonresidents are taxed on China-source income.

Distinguishes domicile from citizenship; income source rules apply regardless of payment location for listed categories. There is also a short-stay exemption for some non-domiciled individuals; not exhaustively summarized here.

• Treaty residence conflicts and treaty-specific employment exceptions not reviewed.

Hong Kong profits tax follows the territorial source principle and generally taxes profits arising in or derived from Hong Kong. Offshore status is a fact-based source question, not determined merely by customer or payment location. Under the FSIE regime, specified foreign-sourced dividends, interest, IP income and disposal gains from all types of property (expanded beyond equity interests from January 2024) received in Hong Kong by in-scope MNE entities may be deemed taxable unless an applicable economic-substance, participation, nexus or intra-group-transfer exception applies.

Scope is principally source-based; incorporation/nationality does not by itself establish the source of profits.

• Detailed FSIE economic-substance and participation conditions were not independently tested against each fact pattern; source is not a legal determination.

Individual taxation is source-based by income category. Salaries tax principally covers employment income arising in or derived from Hong Kong; it is not restricted to residents, and a nonresident may be liable for services rendered in Hong Kong. Employment-source tests and apportionment/visit rules can affect the result, so residence alone does not determine liability.

Hong Kong does not generally impose salaries tax solely by individual residence; source and category-specific rules control.

• Full individual income-category scope and detailed employment source/apportionment cases not surveyed.

An Australian-resident company is generally within the worldwide-income system. Corporate tax residence is determined under statutory tests, including Australian incorporation and, for a foreign-incorporated company, carrying on business in Australia plus central management and control in Australia, or Australian-resident shareholder voting control; nationality/incorporation alone is not a complete test. Certain foreign-branch profits and qualifying non-portfolio dividends may be non-assessable non-exempt.

Do not infer tax residence solely from company nationality or place of incorporation; multiple statutory tests apply.

• Current exhaustive statutory residency tests and all foreign-income exemptions were not surveyed; ATO business-overseas page last updated 2016.

An Australian tax-resident individual generally declares worldwide income; a nonresident is generally taxed on Australian-source income. Residence follows tax-residence tests, not Australian citizenship alone. A resident who qualifies as a temporary resident is generally exempt on much foreign income, subject to exceptions including certain foreign employment income; foreign income tax offsets may apply.

ATO guidance emphasizes tax residence is not the same as citizenship; temporary-resident status is a separate conditional overlay.

• Full statutory residence tests, temporary-resident eligibility criteria and all foreign-service exceptions not exhaustively analyzed.

A corporation with its registered seat or place of management in Austria is generally subject to unlimited corporation-tax liability on worldwide income. Foreign income may receive treaty relief, commonly exemption or credit depending on the treaty; treaty residence tie-breakers can alter taxing rights. A nonresident corporation is generally subject to limited liability for specified Austrian-source/PE income.

Domestic unlimited tax liability attaches to corporations with seat or place of management in Austria; a foreign-incorporated company's nationality/incorporation alone is not conclusive. Treaty dual-residence rules may override domestic allocation of taxing rights.

• No inventory of individual treaty exemptions/credit rules or foreign-source income categories reviewed.

Individuals with a dwelling or habitual abode in Austria are generally subject to unlimited income-tax liability on domestic and foreign income. Nonresidents are generally limited to enumerated Austrian-source income. Treaties or domestic relief can exempt or credit foreign income; worldwide scope does not mean every item is ultimately taxed twice or without relief.

Unlimited liability arises from an Austrian dwelling/residence or habitual abode; after six months, liability begins retroactively. BMF explicitly says citizenship is not decisive. A narrow EU/EEA high-income option exists for some without Austrian residence.

• The full §98 list of nonresident Austrian-source income and all treaty-specific foreign income reliefs were not surveyed.

A profit-making legal entity with its registered office or principal place of business/management in Belgium is generally within Belgian corporate income tax on its profits from business in Belgium or abroad. Treaty relief and domestic exemptions may apply to particular foreign income, branches, property or distributions. A nonresident may be taxed on specified Belgian-source income.

Belgian-law or foreign-law legal entities may fall within Belgian corporate income tax where their registered office or principal place of business/management is in Belgium and they conduct profit-making activity; legal form, exemptions and legal-entity-tax status matter. Incorporation alone is not a complete cross-border residence determination.

• A complete statutory company-residence test, foreign-branch exemption and participation-exemption conditions were not reviewed; the cited guidance is an administrative overview.

Belgian resident individuals generally report foreign income, but a treaty or domestic rule may provide full or partial exemption; declaration does not mean the foreign income is always ultimately taxed in Belgium. Nonresidents with Belgian income may be subject to nonresident income tax.

This is the resident-individual classification. Residence is a factual tax-residence/domicile question; nationality is not treated as the sole test. Nonresidents with Belgian-source income use nonresident income tax instead.

• The current detailed Belgian tax-residence test and category-by-category foreign-income treaty outcomes were not examined; this record does not claim every worldwide item is taxable after treaty relief.

An Irish-resident company is chargeable to corporation tax on worldwide profits. A nonresident company is generally within the charge on Irish branch/agency trade profits and specified Irish-source income. Double-tax relief and a qualifying foreign-distribution participation exemption can modify the result. Irish-incorporated companies from 2015 are generally resident unless treaty-resident elsewhere.

Irish-incorporated companies are generally Irish tax resident unless a treaty treats them as resident elsewhere. The transition for pre-2015 incorporation ended on 31 December 2020. Foreign-incorporated companies centrally managed and controlled in Ireland are resident under the management-and-control rule.

• Individual treaty residence outcomes and all foreign-income exemptions/credits were not exhaustively checked.

An individual resident and domiciled in Ireland is generally taxable on worldwide income. A resident but non-Irish-domiciled individual is generally taxed on foreign income to the extent remitted to Ireland (remittance basis). A nonresident may remain taxable on some foreign income if ordinarily resident and domiciled, subject to exclusions for certain work performed wholly abroad and small foreign investment income. Residence generally uses 183 days in a tax year or 280 days over two years; ordinary residence and domicile are separate tests.

Residence uses 183 days in a tax year or 280 days across current and preceding year (with 30-day rule). Domicile and ordinary residence separately affect foreign-income scope. Tax residence is not nationality.

• Personal-income categories, temporary nonresident reliefs and treaty-specific outcomes were not exhaustively analyzed.

Older official guidance describes worldwide profits for resident companies, but its direct scope statement dates to 2008. Current residence guidance was located; the current scope classification remains unverified pending a current direct source.

Dutch-law incorporated entities are generally established in the Netherlands under the Corporate Income Tax Act; foreign entities' tax establishment depends on facts including place of management, head office and shareholder meetings. Rules for certain entity types changed in 2025.

• The direct worldwide-profit wording found is in 2008 official Tax Administration material; the current liability page confirms residence tests but does not restate the worldwide base. Current foreign-branch/participation exemption details were not surveyed.

Dutch resident individuals report worldwide income, including Dutch and foreign income. Treaty or domestic double-tax relief may exempt foreign income or grant a deduction, so reporting scope differs from final Dutch tax. Nonresidents are generally taxed only on income from/in the Netherlands that Dutch law and treaties allow the Netherlands to tax.

The Belastingdienst describes a person who lives in the Netherlands as a resident taxpayer; factual residence indicators include permanent home, time spent, family, work and insurance. Nonresidents are taxed on income from/within the Netherlands, subject to treaty limits. Citizenship alone is not the test.

• Detailed residence fact patterns, special tax regimes and all treaty relief methods were not surveyed.

Polish CIT taxpayers with a registered office or place of management in Poland are generally taxed on all income regardless of source location. Nonresident taxpayers are limited to income earned in Poland. Treaty relief may modify the result.

CIT taxpayers with registered office or place of management in Poland are subject on all income regardless of where earned; nonresident taxpayers are limited to Poland-source income. Treaty relief may modify taxing rights.

• Detailed treaty allocation and exemptions were not reviewed.

Polish residents are generally within scope on income earned in Poland and abroad. Residence is based on a centre of personal/economic interests in Poland or presence for more than 183 days in the tax year. Treaties can provide exemption with progression or proportional foreign-tax credit; nonresidents generally have limited Polish-source liability.

Residence test is centre of personal or economic interests in Poland or presence for more than 183 days in the tax year; treaties can affect residence and foreign-income method. Nonresidents generally face limited liability on Polish-source income.

• Individual treaty outcomes and income-specific exemptions were not exhaustively reviewed.

Legal persons with permanent residence in Iceland have unlimited tax liability under Articles 1 and 2 of the Income Tax Act; nonresidents have limited liability for specified Iceland-source income under Article 3. Residence is fact-based (including place of management and closer business/personal relations), and treaties can restrict Iceland's taxing right. The authority says 'unlimited' for legal persons but the reviewed text does not expressly say worldwide income; the precise foreign-income scope remains to be confirmed.

Legal persons with permanent residence in Iceland have unlimited liability under Income Tax Act Articles 1 and 2; nonresident entities are under limited liability for enumerated Iceland-source income under Article 3. Permanent residence depends on domicile/residence, place of management or similar circumstances and closer business/personal relations; treaty relief may restrict Iceland's taxing right.

• The reviewed official text does not expressly state that resident legal persons are taxed on worldwide income; foreign-income scope should not be treated as fully verified from the word 'unlimited' alone.

An individual present in Iceland for six months or more in a twelve-month period is resident from arrival and has unlimited liability; the authority expressly says tax applies to worldwide income. Former residents generally remain liable for three years after departure unless they prove tax liability in another country. Shorter stays generally face Iceland-source limited liability, subject to treaty restrictions.

An individual staying in Iceland for six months or longer within a twelve-month period is treated as resident and has unlimited liability from arrival. Former residents remain liable for three years after departure unless they prove tax liability in another country. Shorter stays generally result in limited Iceland-source liability. Treaties may restrict tax.

• Detailed treaty residence tie-breakers and category-specific foreign-income relief were not surveyed.