Individuals are considered residents of Estonia if they have a permanent residence in Estonia, their stay in Estonia during any 12-month period exceeds 183 days, or they are Estonian public servants who are sent abroad on assignment. An individual may be deemed to have become a tax resident from the date of one’s arrival to Estonia. For the purposes of determining the number of days, any part of a day counts as a full day.
If the tie-breaker article in an applicable double tax treaty (DTT) allocates the residence of a dual-resident individual to a foreign country (most often if the home and family of the individual remain abroad during an assignment to Estonia), then the individual will be taxed as a non-resident in Estonia regardless of the above-mentioned Estonian domestic rule.
The change of tax residence must be notified to the Tax and Customs Board.