Venezuela Guía de ISLR Corporativo 2026

Corporate Income Tax Rate Schedule

Venezuela applies differentiated corporate income tax rates depending on the industry:

• General rate: 34% on net taxable income for most corporations
• Petroleum (primary extraction): 60% on income from primary hydrocarbon extraction activities
• Petroleum (mixed companies): 50% for mixed companies (empresas mixtas) in the hydrocarbon sector
• Mining: 40% on income from mining activities (gold, coal, bauxite, etc.)
• Banking and insurance: 40% on income from financial and insurance activities

The rate applies to net taxable profit (enriquecimiento neto), determined according to the Income Tax Law (Ley de Impuesto sobre la Renta). Fiscal years follow the calendar year unless a different fiscal year is authorized by SENIAT.

Dividend Withholding Tax (WHT)

• Rate: 34% on the gross amount of dividends or profit distributions paid to individuals (resident or non-resident) and foreign beneficiaries.
• Base: Dividends are paid out of after-tax profits. The combined effective rate is approximately 1 - (1 - 0.34) x (1 - 0.34) = 56.44%.
• Exemptions: Dividends paid between Venezuelan corporations are generally exempt. Dividends reinvested in the company may qualify for deferral.
• Non-residents: Subject to the same 34% WHT rate on dividends, unless a tax treaty provides a reduced rate.

Controlled Foreign Corporation (CFC) Rules

• Venezuela has CFC rules that attribute passive income of foreign-controlled entities to the Venezuelan controlling shareholder when the foreign entity is located in a low-tax jurisdiction.
• Passive income includes interest, dividends, royalties, rental income, capital gains, and certain other investment income.
• The Venezuelan shareholder must include the CFC's passive income in their own taxable income on an accrual basis, regardless of actual distribution.
• Active business income of foreign subsidiaries is generally not attributed until distributed.
• Venezuela maintains a list of low-tax jurisdictions and countries with privileged tax regimes.

Branch Profits and Permanent Establishments

• Foreign companies operating through a branch or permanent establishment (PE) in Venezuela are subject to the standard 34% corporate rate on profits attributable to the Venezuelan PE.
• Branch profits remitted to the head office are treated similarly to dividends and subject to 34% WHT.
• The repatriation of branch profits requires approval from the Central Bank of Venezuela (BCV) and is subject to exchange control regulations.

Tax Depreciation and Amortization

• Fixed assets: Depreciated using the straight-line method over their estimated useful lives (buildings 25 years, machinery 10 years, vehicles 5 years, computers 3 years).
• Intangible assets: Amortized over their useful life or the legal protection period, whichever is shorter.
• Inflation adjustment: Venezuela applies a tax inflation adjustment (reexpresión monetaria) based on the National Consumer Price Index (Índice Nacional de Precios al Consumidor or INPC). This adjusts the tax basis of fixed assets, inventories, and equity for inflation.

Tax Loss Carryforward

• Operating tax losses can be carried forward for up to 3 fiscal years.
• Losses must be adjusted for inflation using the monetary re-expression mechanism before carryforward.
• No carryback of losses is permitted.
• Losses may only offset up to 25% of taxable income in any given year (subject to certain exceptions).

FAQs

What is the effective combined tax rate on corporate profits distributed as dividends?

For 2026, the combined rate is approximately 56.44%: 34% at the corporate level, then 34% WHT on the remaining 66%, giving an effective rate of 1 - (0.66 x 0.66) = 56.44%.

Are there transfer pricing rules in Venezuela?

Yes, Venezuela has transfer pricing rules aligned with OECD guidelines. Transactions with related parties must be at arm's length. Documentation requirements include a local report and master file for groups exceeding certain thresholds.

What is the monetary re-expression adjustment?

Companies must apply a tax inflation adjustment (reexpresión monetaria) based on the INPC. This adjusts assets, liabilities, and equity for inflation, recognizing inflationary gains or losses in taxable income.

Aviso Legal

Este guia fornece informações gerais sobre o imposto corporativo na Venezuela para 2026. Leis e alíquotas podem mudar. Sempre consulte um contador ou o SENIAT para orientação específica. InvestmentKit não fornece aconselhamento tributário.