Estonian CIT versus the decision on support in the Polish Investment Zone

Estonian CIT versus the decision on support in the Polish Investment Zone – the latest interpretation by the Director of the National Tax Information Service and its significance for entrepreneurs

Corporate tax, Trochę o CIT

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…

Estonian CIT and the employment condition – tax authorities versus the Supreme Administrative Court

Estonian CIT and the employment condition – tax authorities versus the Supreme Administrative Court

INSIGHT, Trochę o CIT

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…

Practical significance of the explanations of 3 July 2025 concerning WHT in relation to the LTA concept

Practical significance of the explanations of 3 July 2025 concerning WHT in relation to the LTA concept

Corporate tax, Trochę o CIT

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…

The concept of shared personal and asset substance in the new WHT Explanations

The concept of shared personal and asset substance in the new WHT Explanations

Corporate tax, INSIGHT, Trochę o CIT

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…

Estonian CIT and company reorganisations – new protective opinion from the Head of the National Revenue Administration

Estonian CIT and company reorganisations – new protective opinion from the Head of the National Revenue Administration

Corporate tax, Trochę o CIT

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…

Substance related to assets and personnel as a key element of actual economic activity in light of the 2025 Withholding Tax Explanations

Substance related to assets and personnel as a key element of actual economic activity in light of the 2025 Withholding Tax Explanations

Corporate tax, Trochę o CIT

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…

Economic power in light of the WHT Explanations – is this the end of uncertainty?

Economic power in light of the WHT Explanations – is this the end of uncertainty?

Corporate tax, Trochę o CIT

On 9 July 2025, the Minister of Finance published the long-awaited tax explanatory notes regarding so-called beneficial owner clause for withholding tax purposes (hereinafter: WHT Explanatory Notes). Their publication is of significant importance for withholding tax remitters and taxpayers who, since 2022, have been and continue to be particularly exposed to increased controls and proceedings…