Article 12 – Corporate Tax Base

1. A Resident Person, which is a juridical person, is subject to Corporate Tax on its Taxable Income derived from the State or from outside the State, in accordance with the provisions of this Decree-Law.

2. The Taxable Income of a Resident Person, which is a natural person, is the income derived from the State or from outside the State insofar as it relates to the Business or Business Activity conducted by the natural person in the State as set out in Clause 6 of Article 11 of this Decree-Law.

3. A Non-Resident Person is subject to Corporate Tax on the following:

1. 1. The Taxable Income that is attributable to the Permanent Establishment of the Non-Resident Person in the State.
   2. State Sourced Income that is not attributable to a Permanent Establishment of the Non-Resident Person in the State.
   3. The Taxable Income that is attributable to the nexus of the Non-Resident Person in the State as determined in a decision issued by the Cabinet pursuant to paragraph (c) of Clause 4 of Article 11 of this Decree-Law.