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…
On 23 July 2025, the International Court of Justice (ICJ) issued an advisory opinion concerning the obligations of states with regard to climate protection. This case originated from an initiative by students from the Pacific Island Students Fighting Climate Change, who demanded actions to protect islands threatened with extinction due to climate change. The initiative…
The latest explanations issued by the Ministry of Finance on 3 July 2025 regarding withholding tax (hereinafter: the WHT Explanations) clarifies that an entity may be recognised as the beneficial owner of a payment even if it relies on the so-called shared personal and asset substance, i.e. the personnel or infrastructure of other companies within…
On 1 August 2025, the Head of the National Revenue Administration issued a protective opinion (ref. DKP16.8082.1.2025), which is of significant importance for companies planning to switch to Estonian CIT after undergoing reorganisation. In the case in question, the authority found that the redemption and sale of shares leading to the elimination of an investment…
Asset and personnel substance is one of the most important elements in determining the status of the beneficial owner [hereinafter: ‘BO’] for the purposes of withholding tax [hereinafter: ‘WHT’]. The tax explanations published on 3 July 2025 by the Polish Ministry of Finance concerning the application of the so-called beneficial owner clause for withholding tax…
“Debt analysis,” “debt capacity,” “analysis of debt servicing ability” – many terms exist in the world of transfer pricing, but they all refer to the same issue. It is no longer a secret that tax authorities, when examining financial transactions, check not only the level of applied interest rates but also other conditions, including the…