Last chance to prepare the 2024 Local File!
Local File 2024: discover why the reliable preparation of transfer pricing documentation and consistency with the Transfer Pricing Regulation (TPR) are essential for tax security.
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.…
TP Obligations 2024: deadlines, documentation and consequences for taxpayers
Why TP obligations for 2024 matter for businesses The upcoming autumn marks the need to fulfil transfer pricing obligations for 2024. Businesses are required to prepare the Local Transfer Pricing Documentation (Local File) for 2024 and keep in mind the upcoming deadlines relating to the TPR form and the Group Transfer Pricing Documentation (Master File).…
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…
Family foundations – draft tax changes from 2026
The Ministry of Finance has published draft amendments to the Family Foundation Act, which are to come into force on January 1, 2026. Key changes concerning family foundations Taxation of the sale of assets within 36 months of acquisitionThe foundation will pay 19% CIT on income from the sale of property donated by the…
Cash pooling and withholding tax in light of the WHT Explanatory Notes of July 3, 2025 – question without answers
The modern world of finance is dominated by liquidity management. Companies, especially those belonging to international capital groups, focus on centralization in order to effectively manage cash surpluses and deficits. Cash pooling, a system that enables cash flow management within a group, is becoming not only a popular but also a key tool in this…
Estonian CIT under scrutiny by tax authorities
The data presented in the Ministry of Finance’s response to a parliamentary question[1] is a warning sign for entrepreneurs that the correct application of Estonian CIT rules may be more challenging than many of them had anticipated. The information presented shows that the tax authorities’ practice of verifying lump sum settlements is extremely restrictive. In…