Change of taxation form to Estonian CIT A company may opt for Estonian CIT taxation during the tax year, provided that it closes its accounting books and prepares financial statements in accordance with the Accounting Act on the last day of the month preceding the first month of lump-sum taxation. In practice, the tax authorities…
The departure of the Estonian CIT has led to a number of concerns being raised among entrepreneurs. Following the termination of the lump-sum tax on corporate income, what is the subsequent course of action for the tax? When does the tax obligation arise and how can costly mistakes be avoided? The answers are provided by…
WHT explanations – have holding companies gained understanding in withholding tax? What is the opinion of MDDP experts?
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.…
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…
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…
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…
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.…
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…
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…