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...

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...

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...

In business practice, situations frequently arise in which one entity incurs the cost of a service or goods and subsequently passes it on to another entity. A classic example is the so-called re-invoice – i.e., the resale of a service without adding one’s own margin, usually “at cost.” To...

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...

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,...

Transfer pricing back in the spotlight. New presidential initiative could mean more audits A change in the Presidential Palace often signals a shift in economic and tax policy. This time, alongside the widely publicised proposal to introduce tax relief for families raising at least...

On 4 August 2025, the Ministry of Finance published a new draft amendment to the Tax Ordinance. This continues the work on changes to tax regulations that began in March 2025. What changes to the Tax Ordinance does the latest draft amendment provide? We have selected some of the most...

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...

Ministry of Finance announces changes in the taxation of family foundations from 2026 On 8 August 2025, representatives from the Ministry of Finance and the Ministry of Economy announced an increase in the taxation of family foundations. According to the Ministry’s declarations,...

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...

“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...

GloBE – automatic exchange of information – first signatories of the multilateral agreement (GIR-MCAA) and other tools for handling GloBE. On 6 August 2024, a list of 14 signatories to the multilateral agreement on information exchange GloBE (GIR-MCAA, GloBE Information Return-Multilateral...

On August 1, 2025, the CJEU issued its long-awaited judgment on the reclassification of transactions from intra-Community supply to export in a case concerning a Polish taxpayer (C‑602/24). Facts The case concerns a situation where the initial arrangements between the parties to the...

Work is underway on a new regulation by the Minister of Infrastructure, which will update the rules for reimbursing the costs of using a private vehicle for business purposes (known as mileage rates). The planned changes will not only increase the rates but will also introduce clear...