WHT explanations – have holding companies finally been understood in terms of withholding tax?

WHT explanations – have holding companies gained understanding in withholding tax? What is the opinion of MDDP experts?

Estonian CIT and bond purchases – hidden risk of losing the right to a lump sum regime

Estonian CIT conditions One of the conditions of Estonian CIT is the appropriate structure of the company’s revenues. Passive income may not exceed 50% of total income. Passive income includes, in particular, income from receivables, interest, sureties, guarantees, copyrights, industrial property rights, as well as the sale and exercise of rights arising from financial instruments.…

Hidden gains in the draft amendment for 2026 – what may change in Estonian CIT?

The draft amendment to the income tax laws of September 16, 2025, provides for changes in the regulations concerning the lump sum tax on company income. The recent amendment to the definition of “hidden profits” has generated significant controversy, as it effectively determines which benefits between a company and its shareholders are subject to additional…

Intangible services in withholding tax (WHT)

The CIT Act and the PIT Act contain a list of intangible services, the income from which, as a rule, is subject to a 20% flat-rate income tax (withholding tax / WHT). These services include: consulting, accounting, market research, legal, advertising, management and control, data processing, employee recruitment and personnel acquisition, guarantees and sureties, and…

Dividends and beneficial ownership status – the “safe harbour” mechanism in the Minister of Finance’s explanations

Entities that pay dividends to their parent companies have been struggling for years with documentation challenges when attempting to confirm their right to apply for withholding tax exemption. In Explanations concerning the beneficial owner clause published on July 3, the Minister of Finance proposed a solution that can be described as a “safe harbour.” It…

Redemption of shares under Estonian CIT

When applying Estonian CIT, the question arises as to whether remuneration for the redemption of shares financed from pre-lump sum profits should be treated as hidden profit. This is not an abstract issue – it affects many entities that accumulated significant reserve capital before choosing the lump sum and are now planning to redeem shares.…

Foreign collective management organizations and WHT

One of the issues addressed in the explanatory notes of the Ministry of Finance of July 3, 2025, is the status of collective management organizations for copyright or related rights (hereinafter: CMO). The activities of CMOs consist in the protection of the copyrights and related rights entrusted to them, within the framework of which these…

Estonian CIT – announcement of changes in regulations

The Ministry of Finance has announced modifications to the regulations concerning Estonian CIT. On September 16, 2025, a draft bill amending the PIT and CIT regulations was presented. It appears that for companies applying Estonian CIT, the chosen direction is primarily to increase the tax burden. However, there are also solutions that may resolve existing…