Estonia Tax Treaty

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Estonia Tax Treaty

Estonia International Tax Compliance Rules

Quick Summary.  Located in Northeastern Europe, the Republic of Estonia borders the Baltic Sea, Gulf of Finland, Latvia, and Russia.

Estonia gained independence in 1991 with the fall of the Soviet Union.  It has since become one of the world’s most digitally advanced countries, becoming the first country to hold elections over the internet and to provide e-residency.

The Constitution of Estonia provides for the country’s fundamental law, providing for a unicameral parliament (Riigkogu).  Estonia is a democratic parliamentary republic and is comprised of 15 counties.  It is based on a civil law legal system.

Effective 2019, Estonia implemented the European Union (EU) 2016/1164 Anti-Tax Avoidance Directive (ATAD), providing for controlled foreign company (CFC) rules, a general anti-abuse rule (GAAR), and thin capitalization rules.

Effective in 2010, Estonia has implemented hybrid mismatch rules consistent with EU directives.

Estonia is a member of the North Atlantic Treaty Organization (NATO), the European Union (EU), and the Organisation for Economic Co-operation and Development (OECD).

Income Tax Treaty between the United States and Estonia


Currency. Euro (Eur) 

Common Legal EntitiesPrivate/Public limited company, limited partnership, unlimited partnership, commercial association and branch of a foreign corporation.

Tax AuthoritiesTax and Customs Board, Ministry of Finance

Tax Treaties. Estonia has 59 tax treaties in effect.

Corporate Income Tax Rate.  20% of the gross amount of the profit distribution.

Individual Tax Rate. 20%.

Corporate Capital Gains Tax Rate. 20%.

Individual Capital Gains Tax Rate. 20%.

Corporate residenceResident if established pursuant to Estonian Law. Additionally, European public limited companies and associations with registered seats in Estonia are deemed to be resident.

Individual residence. Individual is resident if place of residence is in Estonia or stays in Estonia for at least 183 days over 12 consecutive months (deemed to be resident as of date of arrival in Estonia).

Withholding Tax.

            Dividends. – 0%.

            Interest. – 0%. Exception for interest derived by a nonresident investor from Estonian pools of assets.

            Royalties. – Residents: 0% Nonresidents: 10%.

            Commissions. – 0%/10%.

Transfer Pricing. If transactions conducted between a resident legal person and a person associated with that person differ in value from similar transactions between non-associated persons, income tax is charged on the income the taxpayer would have derived or expense the taxpayer would not have incurred had the transaction been conducted with unrelated persons.

CFC Rules.  Apply when certain conditions are fulfilled.

Hybrid Treatment.  N/A

Inheritance/estate tax.  None.

Tax Treaty Network – International Tax Attorneys

Our international tax expertise allows us to guide clients through tax planning and compliance so that they can focus on what matters most. At Freeman Law, our clients are engaged in an interconnected business environment that spans across the globe.  From supply chains to markets, cross-country taxation impacts every global business.

Do you have questions about Estonia’s Tax Treaties? Schedule a free consultation with one of Freeman Laws International Tax Experts Today!