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…
Reimbursement of travel expenses for board members is, as a rule, exempt from income tax (PIT) and social security contributions.
As part of our series TP and VAT, where we discuss key issues concerning intra-group transactions (Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT | MDDP), we covered the Arcomet case (C-726/23) and the opinion of the Advocate General of the CJEU (A new perspective from the…
The tax Guidelines published by the Ministry of Finance concerning the application of the so-called beneficial owner clause for withholding tax purposes (hereinafter: Guidelines) are intended to clarify the rules for applying this clause in the context of the withholding tax collection obligation. One of the issues that has raised doubts in the past was…
The Voivodship Administrative Court in Gliwice, in a non-final judgment (ref. III SA/Gl 895/24), upheld the position of the tax authorities and ruled that disinfectant liquid is subject to excise duty. Why is excise duty on biocidal alcohol controversial? Recently, excise duty on alcohol used in biocidal products has become a subject of dispute between…
Since 2021, it has been possible to conduct business activity in the form of a simple joint-stock company (PSA). The PSA was intended to address the challenges of the modern economy – no barriers to entry, simplified profit distribution and faster liquidation, in short – the ideal legal form for start-ups. However, entrepreneurs still approach…
For many entrepreneurs, Estonian CIT means an opportunity for simplified settlements and greater financial liquidity, but at the same time – a number of conditions to be met. One of them is the prohibition of combining Estonian CIT with the privileges resulting from the decision on support within the Polish Investment Zone (PSI). The latest…
Several weeks ago, this blog provided commentary on the Supreme Administrative Court ruling of 15 May 2025 (ref.). II FSK 163/25 [1] provided a clear definition of the interpretation of the employment condition in Estonian CIT. The Supreme Administrative Court ruled that the requirement of 300 days of employment per year should be applied to…
The tax explanations concerning the application of the beneficial owner (BO) clause significantly clarify and, we hope, will facilitate the application of the look-through approach (LTA). The application of the LTA may prove crucial for international capital groups where WHT-taxable receivables are transferred in a payment chain between several related entities. What is the LTA…
TPR (Transfer Pricing Report) is a key obligation for taxpayers carrying out transactions with related entities. Its purpose is to provide the tax authorities with essential information about transactions, including the reported profitability. TPR reporting is not merely a formality – it is a tool that enables quick insight into transactions and facilitates the selection…