Tax residence in Estonia
Income that is subject to income tax in Estonia
Exemptions
Various items are excluded from the taxable income of residents, including, but not limited to, the following:
- Inheritances received (accepted succession)
- Gifts received from other individuals, state or local government authorities, resident legal persons or nonresidents through or on account of their permanent establishment registered in Estonia
- Insurance proceeds received under specific insurance contracts
- Dividends received from resident companies except dividends taxed at a lower rate under a special three-year distribution rule
- Dividends received from nonresident companies, if income tax was paid on the share of profits out of which the dividends were paid or if income tax on the dividends was withheld in a foreign country
- Income from the exchange of a holding (for example, shares) in the course of a merger, division or transformation of companies or nonprofit associations or a merger of investment funds
- Income from the increase or acquisition of a holding in a company through a non-monetary contribution
- Income from the exchange of units of an investment fund
- Income from transfers of movable property used for personal purposes
- Gains derived from transfers of real estate, structures or apartments treated as movables or as contributions to housing associations if the asset is privatized under government order, is received as restitution for the unlawful alienation of property or is used as the taxpayer’s primary or permanent place of residence
- Gains derived from transfers of summer cottages or garden houses owned by residents for more than two years if the size of the land related to the cottage or house does not exceed 0.25 hectares
- Employment income and service fees for working in a foreign state if the individual has stayed in the foreign state for the purpose of employment for at least 183 days during a period of 12 consecutive calendar months and if the relevant income has been included in the taxable income of the person in the foreign state and this is certified, with the amount of income tax indicated on the certificate (even if the amount is zero)
- Per diem allowances and accommodation costs of business trips, and compensation for business use of a private car, in accordance with the prescribed rates
- Childbirth allowances paid by an employer to an employee or public servant, in an amount not exceeding EUR 2,500
- In-service training and retraining of employees paid for by the employer on termination of the employment or service relationship as a result of redundancy
- Payments at prescribed rates by an employer for the treatment of damage caused to the health of an employee or public servant as a result of an accident at work or an occupational disease
- Payments made to diplomats on the basis of the Foreign Service Act
- Benefits paid to victims of crime under the law
- Gambling winnings received from gambling organized on the basis of an operating permit or registration
- Pensions in accordance with the prescribed limits
- Scholarships that are paid by the state or that are mandatory according to the law, if they are not paid with respect to entrepreneurship, employment or management board member status
- Property returned as restitution in the course of ownership reform.
In addition, compensation for certified expenses incurred for the benefit of another person and compensation for direct proprietary damage that is not paid with respect to entrepreneurial activities are not deemed to be taxable income of a resident, except for compensation that is paid subject to separate terms, conditions and limits, such as compensation for the business use of a private car.
Inheritance and gift tax in Estonia
Taxation of Self-employment Income in Estonia
Registered sole proprietors’ income attributable to self-employment or entrepreneurship is subject to income tax and social tax. General partnerships are taxed as separate entities.
Entrepreneur account
An individual not registered as a sole proprietor can open an entrepreneur account (a bank account in a credit institution resident in an EEA member state) for business income simplified taxation. Income derived from selling goods or services transferred to the business income account is subject to business income tax. The business income tax rate is 20% of the total amount received into the entrepreneur account if the amount does not exceed 25 000 euros per calendar year and 40% if the amount exceeds 25 000 euros received into the entrepreneur account per calendar year.
The tax should be automatically calculated, withheld and paid to the tax authorities on a monthly basis by the credit institution. The tax is used to cover all payroll tax obligations applicable to the individual proportionally. VAT registration is forbidden. No separate social security contributions are due. The individual is covered by social security, provided that the tax paid meets the minimum social tax obligation.
Who benefits from the entrepreneur account?
The entrepreneur account is useful for a person who provides services to other private persons in areas of activity that do not involve any direct expenses or who sells self-produced goods with low costs of materials or acquisition to private persons and legal persons.
Such services can be babysitting, housekeeping, gardening, repair or construction services that do not involve direct costs or in which case a customer pays for the costs. For example, a customer orders repair or construction services and buys the necessary tools and materials himself or herself.
Another example is the sale of self-produced goods to private and legal persons if the cost of raw materials or source materials is low compared to the selling price of the goods. Such a case could be the sale of handicrafts and art or the sale of food, plants etc., grown or produced by a private person. The entrepreneur account is also an appropriate solution for the new forms of entrepreneurship, allowing for the simplified taxation of fees paid by one private person to another through ride-sharing service platforms.
Who does not benefit from the entrepreneur account?
Since the total amount received into the entrepreneur account (not only the profit from the provision of services or the sale of goods) is taxed with business income tax, it is impossible to deduct costs or expenses. Therefore, in the areas of activity that involve direct or high costs, operating as a sole proprietor or through a private limited company is more beneficial. For example, when selling or distributing goods, it is important to deduct the acquisition costs from the income.
Taxation of Investment Income in Estonia
Dividends received by residents from resident companies are exempt from tax. However, dividends received from resident companies that are taxed at a lower rate under a special three-year distribution rule are included in the individual’s taxable income. Residents are taxed on all dividends and other profit distributions received from foreign companies unless income tax was paid on the profits from which the dividends were paid or if income tax on the dividends was withheld in a foreign country. Dividends paid to shareholders are not subject to withholding tax. However, dividends paid to individuals (including nonresident individuals) are subject to an additional 7% income tax withholding if those dividends are paid by a resident company and taxed at a 14% corporate income tax rate at the company level. Dividends and profit distributions paid by resident companies are subject to corporate income tax at a rate of 20% at the level of the distributing companies at the moment of the profit distribution. This tax is not a withholding tax and is paid by the company in addition to the amount of dividends distributed.
Rental payments and royalties paid to resident individuals are subject to withholding tax at a rate of 20%. However, if a dwelling is rented out under a rental agreement, under certain conditions, the tax authorities consider 20% of rental income as rental-related costs and only 80% is taxed. This deduction can be applied through the personal income tax return.
Estonian income tax for nonresidents
Nonresident individuals are taxed on the following types of income derived from Estonian sources:
- Income from the alienation or lease of assets registered in Estonia.
- Interest received as a result of ownership of a contractual investment fund if the fund has owned (directly or indirectly) at any time during the two-year period before the date of interest payment more than 50% of real estate located in Estonia and if the interest recipient owns at least 10% of the investment fund unless the profits of the investment fund have been already taxed.
- Royalties and income from sales or licenses of patents, copyrights, trademarks, software, know-how and other information received from Estonian persons.
- Liquidation distributions and payments related to a company’s reduction of its stock capital, to the extent the amount received exceeds the acquisition cost of the shares, except for the portion of the amount received that has been taxed at the level of the company making the payments.
- Salary, wages and other employment income for work performed in Estonia if more than 183 days are spent in Estonia or if the payments are made by a resident or a nonresident registered in Estonia. Nonresident rental employee employment income becomes taxable in Estonia from day one if the user entity is an entity registered in Estonia.
- Income of nonresident board members (this income is taxed even if the remuneration for managing the Estonian company is paid by a foreign company).
- Dividends or other profit distributions received from Estonian resident companies that were taxed at a reduced rate of 14% at the company level.
Nonresidents are exempt from tax on the following types of income:
- Inheritances received (accepted succession)
- Income from the transfer of movable property used for personal purposes
- Expropriation payments and compensation paid on expropriation
- Income from the exchange of a holding (for example, shares) in the course of a merger, division or transformation of companies or nonprofit associations or a merger of investment funds
- Income from the increase in or acquisition of a holding in a company through a non-monetary contribution
- Income from the exchange of units of an investment fund
- Interest received by nonresident individuals from resident credit institutions or branches of nonresident credit institutions entered into the Estonian commercial register
- Per diem allowances and accommodation costs with respect to business trips and compensation for business use of a private car, in accordance with the prescribed rates
- Gains derived from transfers of real estate, structures or apartments treated as movables or as contributions to housing associations if the asset is privatized under government order, is received as restitution for the unlawful alienation of property or is used as the taxpayer’s primary or permanent place of residence
- Gains derived from transfers of summer cottages or garden houses owned by residents for more than two years if the size of the land related to the cottage or house does not exceed 0.25 hectares
Capital gains tax in Estonia
Capital gains derived from selling business property or securities are taxable at a rate of 20%.
Capital gains derived by resident individuals with respect to the following sources are not subject to income tax:
- Transfer of movable property that is in personal use
- Transfer of land and assets returned in the course of ownership reform
- Transfer of a dwelling house or an apartment, if it has been used as a permanent home until transfer (applicable to one transfer of residence during a two-year period), received as restitution or acquired as a result of privatization with the right of pre-emption and if the size of the related land does not exceed two hectares
- Transfer of a summer cottage or garden house if it has been owned for more than two years and if the size of the related land does not exceed 0.25 hectares
- Natural persons can register their bank accounts as investment accounts and defer the taxation of financial income until it is withdrawn from the accounts; that is, it is possible to invest the income gained from some common financial investments without being liable to annual taxation on such income.
Nonresident individuals are taxed on gains derived from the sale of property located in Estonia, excluding transfers of permanent homes under the same criteria described above regarding residents and securities issued by companies registered in Estonia. However, this exclusion does not apply if the transferred holding is a holding in a company, contractual investment fund or other pool of assets and if both of the following circumstances exist:
- At the time of the transfer or during the two-year period before the transfer, more than 50% of the property of the company, fund or pool of assets was directly or indirectly made up of immovables or structures as movables located in Estonia.
- At the time of transfer, the nonresident held at least 10% of the company, fund or pool of assets.
Withholding taxes in Estonia
| Type of payment | Rate (%) |
| Dividends | 0/7 (i) |
| Interest | 20 |
| Wages and salaries | 20 |
| Payments for services rendered in Estonia | |
| By nonresident legal persons from noncooperative tax jurisdictions (ii) | 20 |
| By other nonresidents | 10 |
| Royalties | |
| Paid to residents | 20 |
| Paid to nonresidents | 10 |
| Rent | 20 |
| Payments made to nonresident athletes and artists | 10 |
| Supplementary and voluntarily funded pension payments | 10 |
| (i) The 7% withholding tax rate applies to dividends or other profit distributions received from Estonian resident companies that were taxed at a reduced rate of 14% at the company level. | |
| (ii) Income derived from services provided to an Estonian resident is taxed in Estonia regardless of where the services are provided or used. | |
Income tax deductions in Estonia
The standard income tax rate is a flat rate of 20%. The basic annual exemption ranges regressively from nil to EUR 6,000, depending on the amount of the individual’s income. Estonian residents, as well as residents of other EEA member states who derive their taxable income from Estonia and file an income tax return in Estonia, may claim deductions for the following items:
- Gifts to nonprofit organizations registered as tax-favoured in the EEA.
- Mandatory social security payments made in Estonia or abroad from income taxable in Estonia.
- Acquisition of voluntary pension fund units registered in the EEA, limited to 15% of income for the tax year or to EUR 6,000, after subtracting the deductions from business income (joint limits with the employer making such payments on behalf of an employee).
- Training expenses, include costs of educating individuals and their dependents who are under 26 years old and permanent residents of Estonia who are under 26 years old and in certified educational institutions or license training. For adults, the deductions are available only for expenses for formal education, and certain additional limitations apply to driver’s license training and hobby school costs.
- Interest paid to EEA credit institutions on housing loans for the purpose of acquiring an apartment, dwelling house or a plot of land to build a house for personal use (including erection, expansion and reconstruction of a home). The total amount of deductible gifts, housing loan interest and training expenses for a tax year is limited to EUR 1,200 or 50% of an individual’s income after business deductions. Housing loan interest is deductible up to EUR 300.
- An increased basic exemption of up to EUR 5,000 can be deducted from the income derived from the sale of timber felled from an immovable belonging to a forest owner, the transfer of the right to cut the standing crop growing there and Natura 2000 support for private forest land after the deductions related to forest management have been made.
- In addition to the above deductions, the following tax exemptions apply for each tax year under the same circumstances:
- Basic tax exemption in 2023. The amount is EUR 7,848 if the annual income is up to EUR 14,400. However, if income exceeds EUR 14,400, the amount of basic tax exemption is calculated using the following formula:
- 7,848 – 7,848 × (income amount – EUR 14,400) / 10,800 If annual income exceeds EUR 25,200, no basic exemption applies.
- Basic tax exemption in 2023. The amount is EUR 7,848 if the annual income is up to EUR 14,400. However, if income exceeds EUR 14,400, the amount of basic tax exemption is calculated using the following formula:
- A resident in Estonia and a resident of another state that is a contracting party to the EEA agreement may take deductions into account regardless of the share of the income derived from a foreign state.
- Deductions do not apply to crew member remuneration, which is subject to a 0% income tax, including basic tax exemption, additional tax exemption for the provision of maintenance to a child, increased basic exemption for spouse, interest paid on housing loans, training expenses, gifts and donations, insurance premiums, acquisitions of pension fund units and mandatory social security contributions.
- Business deductions. Registered individual entrepreneurs may deduct documented expenses directly related to entrepreneurial or self-employment activities, including expenses for work-related advanced training and retraining of employees and losses incurred from the disposal of assets (except for losses incurred on the sale of securities). If certain expenses are only partly related to the entrepreneurial or self-employment activities, only the part directly related to those activities is deductible.
- Documented expenses for entertainment, recreation, reception (catering, transport or cultural expenses incurred to serve clients or business partners), and other expenses incurred for clients or business partners with respect to entrepreneurial or self-employment activities may be deducted from income up to a maximum amount of 2% of adjusted income. Adjusted income is financial income after adjustments for nontaxable income and expenses that are not deductible for tax purposes.
Tax credits in Estonia
Foreign dividends and employment income are exempt from tax in Estonia if these types of income are taxable abroad. Residents may claim a credit for foreign tax paid, up to the amount of Estonian tax attributable to the foreign-source income. Income tax is calculated separately for income derived in Estonia and for income derived in each foreign country. The individual must pay in Estonia the difference between the foreign income tax and Estonian income tax if the income tax calculated on income derived from abroad exceeds the amount of income tax paid in the foreign country. The overpaid amount of income tax abroad is not refunded in Estonia. If the income tax on income derived in a foreign country is paid during a tax year other than the tax year in which the income is derived, the foreign income tax is taken into account in Estonia during the tax year in which the income taxable in a foreign country is received.
Relief for losses.
Losses from entrepreneurship, except losses incurred on the sale of securities and receivables, may be offset against income derived from other sources of entrepreneurship. Losses may generally be carried forward for seven years. However, losses incurred on the sale of securities may offset only income from the sale of securities and may be carried forward indefinitely.
Social security and social tax in Estonia
Social security and social tax in Estonia
- Social Security contributions – Social tax is levied on employers at a rate of 33%; employees are not liable for social tax. No ceiling applies to the amount of salary subject to social tax.
- In addition, unemployment insurance and pension fund (if one has joined) charges are imposed on gross salary. The unemployment insurance rates are 0.8% for employers and 1.6% for employees.
- The pension fund rate is 2%, which applies only to employees. Employers withhold unemployment insurance and pension fund charge. The pension fund is not mandatory, and one can opt to leave or not join the pension fund. Individuals who have not joined can join. Also, individuals can withdraw and use the money accumulated in the pension fund before reaching the pensionable age. The money withdrawn from the fund before pensionable age is subject to income tax at 20%. If the money is taken out after pensionable age, a lower tax rate of 10% or a tax exemption may apply on certain conditions.
Totalization agreements
Estonian social security legislation follows the rules provided in European Council Regulation No. 883/2004, the Brexit Withdrawal Agreement and the agreement between the European Union (EU) and the European Atomic Energy Community and the United Kingdom. Estonia has applicable totalization agreements on social security with Australia, Belarus, Canada and Ukraine. It has agreements regarding pension insurance regulation with Moldova and the Russian Federation.
Social tax for Self-employed
Self-employed persons must pay social tax at a rate of 33% on their net business income, subject to a maximum amount of annual income equal to 10 times the sum of the minimum monthly wages for the tax year (maximum amount of EUR 78,480 for 2022). Self-employed persons must make quarterly advance payments of social tax to the Tax and Customs Board by the 15th day of the third month of the second, third and fourth quarters. In 2022, each payment must be at least EUR 578.16 (EUR 2,312.64 for the calendar year).
The tax regime for seamen in Estonia
Income tax for Seamen
A special personal income tax regime for seamen applies, under which a 0% income tax rate is applied to crew member remuneration derived from work done on a ship meeting the following conditions:
- The ship has a gross tonnage of at least 500 and is used for international carriage of goods or passengers by sea, except passenger ships engaged in regular service in the European Economic Area (EEA).
- The ship is flying the flag of an EEA contracting state.
Social tax for Seamen
Special social tax rules apply to remuneration paid to seamen. A reduced social tax rate of 20% and a fixed tax base of EUR 750 per month are applicable for qualifying entities if the following conditions are satisfied:
- The ship has a gross tonnage of at least 500 and is used for international carriage of goods or passengers by sea, except passenger ships engaged in regular service in the EEA.
- The ship is flying the flag of a contracting state.
- Crew member remuneration that is subject to social tax is also subject to unemployment insurance contributions and pension fund contributions.
Taxation of employer-provided stock options
Estonia Double tax relief and tax treaties
Non-residents have a tax liability in Estonia in respect of the income derived exclusively from Estonian income sources. The taxation of non-residents’ income derived in Estonia is influenced by bilateral tax treaties between countries.
- The non-residents’ income derived exclusively from Estonian income sources is taxed in Estonia. The income tax law provides relief for foreign taxes paid up to the amount of Estonian tax imposed on foreign source income.
- Generally, income tax is withheld when disbursement is made and non-residents themselves do not have to submit a tax return. Non-residents have to declare their income themselves if it is received from the transfer of property or as a sole proprietor’s business income or as a registered permanent establishment in Estonia.
Most of Estonia’s double tax treaties follow the Organisation for Economic Co-operation and Development (OECD) model convention.
Estonia has entered into double tax treaties with the following jurisdictions:
List of tax treaties
| Jurisdiction | Initialled | Signed | Ratified | In force | Effective from | |
| 1 | Albania | 15.09.2009 | 05.04.2010 | 27.10.2010 | 25.11.2010 | 01.01.2018 |
| (est/eng) | ||||||
| 2 | Armenia | 02.10.1997 | 13.04.2001 | 11.12.2002 | 23.01.2003 | 01.01.2001 |
| (est/eng) | ||||||
| 3 | Austria | 15.12.1999 | 05.04.2001 | 17.09.2002 | 12.11.2002 | 01.01.2003 |
| (est/eng) | ||||||
| 4 | Azerbaijan | 13.09.2002 | 30.10.2007 | 24.09.2008 | 27.11.2008 | 01.01.2009 |
| (est/eng) | ||||||
| 5 | Bahrein | 06.05.2010 | 12.10.2012 | 11.12.2013 | 23.12.2013 | 01.01.2014 |
| (eng (PDF)) | ||||||
| 6 | Belarus | 27.01.1995 | 21.01.1997 | 25.03.1998 | 22.07.1998 | 01.01.1999 |
| (est/eng) | ||||||
| 7 | Belgium | 15.07.1998 | 05.11.1999 | 11.10.2000 | 15.04.2003 | 01.01.2004 |
| (est/eng) | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 6 of the Protocol of the Convention between Estonia and Belgium, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 8. | Bulgaria | 26.10.2007 | 13.10.2008 | 10.12.2008 | 30.12.2008 | 01.01.2009 |
| (est/eng) | ||||||
| 9 | Canada | 07.07.1994 | 02.06.1995 | 13.12.1995 | 28.12.1995 | 01.01.1996 |
| (eng (92.03 KB, PDF)) | ||||||
| From 1 January 2016 the following types of royalties are exempt from tax in the state in which they arise: (a) copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films nor royalties in respect of works on film or videotape or other means of reproduction for use in connection with television broadcasting); or (b) royalties for the use of, or the right to use, any patent or any information concerning industrial, commercial or scientific experience (but not including any such information provided in connection with a rental or franchise agreement) based on the most-favoured nation clause in paragraph 7 of Article 12 of the Convention between Estonia and Canada, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 10 | China | 19.04.1996 | 12.05.1998 | 09.12.1998 | 08.01.1999 | 01.01.2000 |
| (est/eng) | ||||||
| Protocol | ||||||
| 29.03.2011 | 09.12.2014 | 21.10.2015 | 18.12.2015 | 01.01.2016 | ||
| (est)(eng (PDF)) | ||||||
| 11 | Croatia | 08.10.1999 | 03.04.2002 | 19.05.2004 | 12.07.2004 | 01.01.2005 |
| (est/eng) | ||||||
| 12 | Cyprus | 16.02.2011 | 15.10.2011 | 25.09.2013 | 08.10.2013 | 01.01.2014 |
| (est)(eng (PDF)) | ||||||
| 13 | Czech Republic | 03.03.1994 | 24.10.1994 | 14.12.1994 | 26.05.1995 | 01.01.1996 |
| (est/eng) | ||||||
| 14 | Denmark | 14.01.1993 | 04.05.1993 | 25.11.1993 | 30.12.1993 | 01.01.1994 |
| (est/eng) | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 7 of Article 12 of the Convention between Estonia and Denmark, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 15 | Finland | 14.01.1993 | 23.03.1993 | 25.11.1993 | 30.12.1993 | 01.01.1994 |
| (est/eng) | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 7 of Article 12 of the Convention between Estonia and Finland, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 16 | France | 13.04.1995 | 28.10.1997 | 25.03.1998 | 01.05.2001 | 01.01.1996 |
| (eng (92.57 KB, PDF)) | (retroactively) | |||||
| From 21 May 2006 the interest arising in a Contracting State on a loan of whatever kind granted to an enterprise of that State by a bank of the other Contracting State shall be taxable only in that other State based on the most-favoured nation clause in paragraph 9 of the Protocol of the Convention between Estonia and France, which was triggered by the Amending Protocol of the Convention between Estonia and the Netherlands entering into force from the same date. | ||||||
| From 11 December 2015 the state of residence has the exclusive right to tax interest based on the most-favoured nation clause in paragraph 9 of the Protocol of the Convention between Estonia and France, which was triggered by the new tax treaty entering into force between Estonia and Luxembourg from the same date. | ||||||
| From 11 December 2015 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 10 of the Protocol of the Convention between Estonia and France, which was triggered by the new tax treaty entering into force between Estonia and Luxembourg from the same date. | ||||||
| 17 | Georgia | 25.05.2001 | 18.12.2006 | 21.11.2007 | 27.12.2007 | 01.01.2008 |
| (est/eng) | ||||||
| Protocol | ||||||
| 22.09.2009 | 17.07.2010 | 09.02.2011 | 11.03.2011 | 01.01.2012 | ||
| (est/eng) | ||||||
| 18 | Germany | 07.04.1995 | 29.11.1996 | 04.06.1997 | 30.12.1998 | 01.01.1994 |
| (eng (108.2 KB, PDF)) | (retroactively) | |||||
| 13.07.2018 | 15.12.2020 | 05.05.2021 (eng (PDF)) | 29.06.2021 | 01.01.2022 | ||
| 19 | Greece | 07.02.2002 | 04.04.2006 | 08.11.2006 | 01.08.2008 | 01.01.2009 |
| (est/eng) | ||||||
| 20 | Guernsey | 13.12.2018 | 18.11.2019 | 12.02.2020 (est/eng (PDF)) | 06.08.2020 | 01.01.2021 |
| 21 | Hong Kong | 21.11.2018 | 25.09.2019 | 04.12.2019 (est/eng) (PDF) | 18.12.2019 | in Estonia 01.01.2020, in Hong Kong 01.04.2020 |
| 22 | Hungary | 23.01.2002 | 11.09.2002 | 19.05.2004 | 05.07.2004 | 01.05.2005 |
| + changed through correspondence | (est/eng) | |||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 3 of the Protocol of the Convention between Estonia and Hungary, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 23 | Iceland | 14.01.1993 | 16.06.1994 | 16.11.1994 | 10.11.1995 | 01.01.1996 |
| (est/eng) | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 7 of Article 12 of the Convention between Estonia and Iceland, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 24 | India | 30.06.2010 | 19.09.2011 | 02.05.2012 | 20.06.2012 | Estonia 01.01.2013 |
| (eng (PDF)) | India 01.04.2013 | |||||
| 25 | Ireland | 16.05.1997 | 16.12.1997 | 16.06.1998 | 29.12.1998 | 01.01.1999 |
| (eng) | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 6 of the Protocol of the Convention between Estonia and Ireland, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 26 | Isle of Man | 11.04.2008 | 08.05.2009 | 25.11.2009 | 21.12.2009 | 01.01.2010 |
| (est/eng) | ||||||
| 27 | Israel | 15.06.2007 | 29.06.2009 | 25.11.2009 | 28.12.2009 | 01.01.2010 |
| (est/eng) | ||||||
| 28 | Italy | 20.12.1995 | 20.03.1997 | 25.03.1998 | 22.02.2000 | 01.01.2001 |
| (est/eng) | ||||||
| 29 | Japan | 16.03.2017 | 30.08.2017 | 20.12.2017 | 29.09.2018 | 01.01.2019 |
| (est/eng (617.53 KB, RTF)) | ||||||
| 30 | Jersey | 16.02.2010 | 21.12.2010 | 23.11.2011 | 30.12.2011 | 01.01.2012 |
| (est/eng) | ||||||
| 31 | Kazakhstan | 19.12.1996 | 01.03.1999 | 07.06.2000 | 19.07.2000 | 01.01.2001 |
| (est/eng) | ||||||
| 32 | Korea | 10.12.1999 | 23.09.2009 | 16.12.2009 | 25.05.2010 | 01.01.2011 |
| (est/eng) | ||||||
| 33 | Kyrgyzstan | 22.04.2016 | 10.04.2017 | 20.12.2017 | 07.02.2018 | 01.01.2019 |
| (est/eng (PDF)) | ||||||
| 34 | Latvia | 25.11.1992 | 31.12.1993 | 25.11.1993 | 08.12.1998 | 01.01.1994- |
| (est/eng) | 01.01.2002 | |||||
| 20.09.2001 | 11.02.2002 | 23.10.2002 | 21.11.2002 | 01.01.2002 | ||
| (est/eng) | (retroactively) | |||||
| 35 | Lithuania | 27.11.1992 | 13.09.1993 | 25.11.1993 | 31.12.1993 | 01.01.1994- |
| (est/eng) | 01.01.2006 | |||||
| 18.10.2002 | 21.10.2004 | 12.10.2005 | 08.02.2006 | 01.01.2006 | ||
| (est/eng) | (retroactively) | |||||
| 36 | Luxembourg | 25.04.2002 | 23.05.2006 | 13.12.2006 | 23.01.2007 | 01.01.2008- |
| (est/eng) | 01.01.2016 | |||||
| 20.09.2012 | 07.07.2014 | 11.02.2015 | 11.12.2015 | 01.01.2016 | ||
| (est/eng) | ||||||
| 37 | Malta | 14.01.2000 | 03.05.2001 | 11.12.2002 | 22.01.2003 | 01.01.2004 |
| (est/eng) | ||||||
| 38 | Mauritius | 29.03.2019 | 19.02.2021 | 15.09.2021 (est/ eng) (PDF) | 12.10.2021 | 01.01.2022 |
| 39 | Mexico | 18.11.2011 | 19.10.2012 | 16.10.2013 | 04.12.2013 | 01.01.2014 |
| (eng (PDF)) | ||||||
| 40 | Moldova | 12.07.1996 | 23.02.1998 | 16.06.1998 | 21.07.1998 | 01.01.1999 |
| (eng) | ||||||
| 41 | Netherlands | 01.10.1993 | 14.03.1997 | 05.11.1997 | 08.11.1998 | 01.01.1995 |
| (eng) | ||||||
| Protocol | ||||||
| 11.11.2004 | 14.07.2005 | 31.03.2006 | 21.05.2006 | 01.01.2005 | ||
| (est/eng) | ||||||
| 04.09.2007 | 26.06.2008 | 11.03.2009 | 22.05.2009 | 01.01.2010 | ||
| (est/eng) | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in subparagraph 3 of paragraph X of the Protocol of the Convention between Estonia and the Netherlands, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 42 | North Macedonia | 24.09.2008 | 20.11.2008 | 08.04.2009 | 21.05.2009 | 01.01.2010 |
| (est/eng) | ||||||
| 43 | Norway | 14.01.1993 | 14.05.1993 | 25.11.1993 | 30.12.1993 | 01.01.1994 |
| (est/eng) | ||||||
| From 8 October 2014 the tax treaty between Estonia and Norway was supplemented by the mutual agreement of competent authorities to include Export Credit Norway to the list of institutions in subparagraph a) of paragraph 3 of Article 11. For further information please read the letter from the Royal Ministry of Finance of Norway (62.63 KB, PDF) from 11th of September 2014 and the corresponding letter from the Ministry of Finance of Estonia (39.29 KB, PDF). | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 7 of Article 12 of the Convention between Estonia and Norway, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 44 | Poland | 01.07.1993 | 09.05.1994 | 23.11.1994 | 09.12.1994 | 01.01.1995 |
| (eng (72.31 KB, PDF)) | ||||||
| 45 | Portugal | 03.07.1998 | 13.05.2003 | 19.05.2004 | 23.07.2004 | 01.01.2005 |
| + changed through correspondence | (est/eng) | |||||
| 46 | Romania | 06.02.1998 | 23.10.2003 | 26.10.2005 | 29.11.2005 | 01.01.2006 |
| (est/eng) | ||||||
| 47 | Serbia | 03.04.2009 | 24.09.2009 | 17.12.2009 | 14.06.2010 | 01.01.2011 |
| (est/eng) | ||||||
| 48 | Singapore | 02.10.1998 | 18.09.2006 | 17.10.2007 | 27.12.2007 | 01.01.2008 |
| (est/eng) | ||||||
| Protocol | ||||||
| 26.07.2010 | 03.02.2011 | 23.11.2011 | 30.03.2012 | 30.03.2012 | ||
| (est/eng) | ||||||
| 49 | Slovakia | 15.05.1998 | 21.10.2003 | 26.10.2005 | 29.03.2006 | 01.01.2007 |
| (est/eng) | ||||||
| 50 | Slovenia | 26.10.1999 | 14.09.2005 | 17.05.2006 | 26.06.2006 | 01.01.2007 |
| (est/eng) | ||||||
| 51 | Spain | 13.07.2001 | 03.09.2003 | 15.12.2004 | 28.12.2004 | 01.01.2005 |
| (est/eng) | ||||||
| From 1 January 2005 the interest arising in a Contracting State on a loan of whatever kind granted to an enterprise of that State by a bank of the other Contracting State shall be taxable only in that other State based on the most-favoured nation clause in Article VII of the Protocol of the Convention between Estonia and Spain, which was triggered by the Amending Protocol of the Convention between Estonia and the Netherlands effective from the same date. | ||||||
| From 1 January 2016 the duration for a building site or construction or installation project or a supervisory activity connected therewith to constitute a permanent establishment is extended to twelve months (instead of nine) and the definition does not contain a reference to assembly project based on the most-favoured nation clause in Article III of the Protocol of the Convention between Estonia and Spain, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax interest based on the most-favoured nation clause in Article VII of the Protocol of the Convention between Estonia and Spain, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in Article VIII of the Protocol of the Convention between Estonia and Spain, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 52 | Sweden | 14.01.1993 | 05.04.1993 | 25.11.1993 | 31.12.1993 | 01.01.1994 |
| (est/eng) | ||||||
| From 1 January 2016 the state of residence has the exclusive right to tax royalties and the term “royalties” does not contain a reference to the payments for the use of, or the right to use, industrial, commercial or scientific equipment based on the most-favoured nation clause in paragraph 7 of Article 12 of the Convention between Estonia and Sweden, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland effective from the same date. | ||||||
| 53 | Switzerland | 30.03.2001 | 11.06.2002 | 19.05.2004 | 12.07.2004 | 01.01.2005 |
| (est/eng) | ||||||
| Protocol | ||||||
| 25.04.2013 | 25.08.2014 | 11.02.2015 | 16.10.2015 | 01.01.2016 | ||
| (est/eng) | ||||||
| From 1 January 2005 the interest arising in a Contracting State on a loan of whatever kind granted to an enterprise of that State by a bank of the other Contracting State shall be taxable only in that other State based on the most-favoured nation clause in paragraph 4 of the Protocol of the Convention between Estonia and Switzerland, which was triggered by the Amending Protocol of the Convention between Estonia and the Netherlands effective from the same date. | ||||||
| 54 | Thailand | 25.05.2007 | 25.09.2012 | 11.12.2013 | 23.12.2013 | 01.01.2014 |
| (eng (PDF)) | ||||||
| 55 | Turkey | 09.01.1998 | 25.08.2003 | 19.01.2005 | 21.02.2005 | 01.01.2006 |
| (est/eng) | ||||||
| 56 | Turkmenistan | 21.10.2011 | 28.11.2011 | 13.02.2013 | 15.03.2013 | 01.01.2014 |
| (eng (PDF)) | ||||||
| 57 | Viet Nam | 16.08.2013 | 26.09.2015 | 19.10.2015 | 14.11.2016 | 01.01.2017 |
| (eng (PDF)) | ||||||
| 58 | Ukraine | 02.11.1995 | 10.05.1996 | 11.12.1996 | 30.12.1996 | 01.01.1997 |
| (eng (105.38 KB, PDF)) | ||||||
| 59 | United Arab Emirates | 14.10.2010 | 20.04.2011 | 15.02.2012 | 29.03.2012 | 01.01.2011 |
| (est/eng) | (retroactively) | |||||
| 60 | United Kingdom | 22.10.1993 | 12.05.1994 | 23.11.1994 | 19.12.1994 | 01.01.1995 |
| (eng (106.19 KB, PDF)) | ||||||
| From 21 May 2006 the interest arising in a Contracting State on a loan of whatever kind granted to an enterprise of that State by a bank of the other Contracting State shall be taxable only in that other State based on the most-favoured nation clause in paragraph 6 of the Exchange of Notes of the Convention between Estonia and the UK, which was triggered by the Amending Protocol of the Convention between Estonia and the Netherlands entering into force from the same date. | ||||||
| From 16 October 2015 the state of residence has the exclusive right to tax interest based on the most-favoured nation clause in paragraph 6 of the Exchange of Notes of the Convention between Estonia andthe UK, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland entering into force from the same date. | ||||||
| From 16 October 2015 the state of residence has the exclusive right to tax royalties based on the most-favoured nation clause in paragraph 7 of the Exchange of Notes of the Convention between Estonia and the UK, which was triggered by the Amending Protocol of the Convention between Estonia and Switzerland entering into force from the same date. | ||||||
| 61 | United States of America | 06.06.1997 | 15.01.1998 | 21.10.1998 | 30.12.1999 | 01.01.2000 |
| (est/eng) | ||||||
| 62 | Uzbekistan | 13.05.2011 | 28.09.2012 | 11.12.2013 | 23.12.2013 | 01.01.2014 |
| (eng (PDF)) | ||||||
In preparation:
| Jurisdiction | Initialled | Signed | Ratified | |
| Bosnia and Herzegovina | 02.06.2010 | |||
| Morocco | 29.04.2011 | 25.09.2013 | Ratified by Estonia 15.10.2014 | |
| (est/eng (PDF)) | ||||
| Oman | 05.12.2019 | |||
| Russia | 10.02.2000 | 05.11.2002 | Ratified by Estonia | |
| 19.05.2004 | ||||
| (est/eng) | ||||
| South-Africa | 27.05.1999 | |||
| Qatar | 29.08.2019 | |||
| Tajikistan | 18.06.2015 |
| Pakistan | 21.10.2016 |
Tax filing and tax payment procedures in Estonia