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the distribution of profits. Hence, the tax rate on retained earnings is zero, and distributed profits in gross terms are
taxed at the same rate as personal income, i.e. at 21 % since 2008. This tax rate is applied also to gifts, donations,
non-enterprise expenses and fringe benefits. The system is applied to Estonian resident companies and permanent
establishments of non-resident companies. The 21 % withholding tax applied on the dividends paid to nonresidents was removed as of 1 January 2009. A withholding tax may still apply to other payments to non-residents,
if they do not have a permanent establishment in Estonia or unless the tax treaties provide otherwise. The measures
to reduce fraud and tax evasion include CFC rules and regulations for minimising the use of transfer-pricing
schemes, as well as a withholding tax of 21 % on the payments to off-shore companies for services.
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