Madagascar — Orbitax Country Chapters

background image

Madagascar — Orbitax Country Chapters

Table of Contents

1. FORMS OF DOING BUSINESS

1.1. Main Forms of Doing Business with a Legal Presence

1.1.1. Main Forms of Doing Business

2.1. Main Formation Requirements

3. CORPORATE RESIDENCE

4. PERMANENT ESTABLISHMENTS

4.1. Domestic PE of a Foreign Entity

4.2. PE-Risk Grid for Foreign Entities Involved in Business Activities

4.3. Branch Profit (Deemed Remittance) Tax

5.1. Tax Base for Resident Entities

5.2. Treatment of Foreign Profits / Losses

5.3. Tax Consolidation / Group Treatment

5.4. Tax Base for Non-Resident Entities

5.5. Source Rules with Respect to Income Derived by Non-Residents

5.6. Qualification of Specific Income Categories for Tax Purposes

6. DETERMINATION OF TAXABLE INCOME

6.1. Main Rules Governing the Determination of Taxable Income

6.2. Main Differences between Commercial and Tax Accounting

6.3. Depreciation and Amortization

6.4. Reserves and Provisions

6.5. Deduction of Cross-Border Payments and Non-Deductible Expenses

6.6. Taxation of Foreign-Source Income

7.1. General Rules

8.1.1. Corporate Income Tax

8.1.2. Other Taxes

8.2. Non-Residents

8.2.1. Corporate/Profit Taxes

8.2.2. Withholding Taxes

9. ELIMINATION OF DOUBLE TAXATION

9.1. Unilateral and Treaty Based Methods Available for the Elimination or Mitigation of Double Taxation

10. INCENTIVES AND SPECIAL REGIMES

11. BUSINESS TRANSFORMATION AND RE-ORGANIZATION

12. VAT ON INTERNATIONAL TRANSACTIONS

12.1. VAT on the Supply of Goods by Non-Residents

12.2. VAT on the Supply of Services by Non-Residents

12.3. Refund of VAT to Non-Residents

13. BASE PROTECTION AND ANTI-AVOIDANCE MEASURES

13.1. GAAR and General Anti-Avoidance Measures

13.2. Thin-capitalization and other Restrictions to Interest Deduction

13.3. CFC and Similar Regimes

13.4. Transfer Pricing

13.4.1. Disclosure Requirements

13.4.2. Specific TP Issues

13.4.3. Documentation Requirements

14. TAX MANAGEMENT AND COMPLIANCE

14.1. Books and Records

14.2. Type of Assessment

14.3. Calendar of Important Compliance Events

14.4. Tax Audits

14.5. Interest and Penalties

14.6. Appeal Procedures

5.4. Tax Base for Non-Resident Entities

Non-resident entities operating in Madagascar through a permanent establishment (‘PE’) are subject to tax on income sourced from Madagascar. Non-resident entities deriving income from sources in Madagascar without a PE are subject to withholding tax on their income (See Sec 8.2.2. below for tax rates).

AuthorOrbitax
CountryMadagascar
Updated21 October 2021
More from Orbitax
Tax News & Alerts
Expert Corner
Corporate Tax Rates
Withholding Tax Rates
Tax Treaties
Country Chapters