Estonia

Corporate - Tax administration

Last reviewed - 03 January 2020

Taxable period

The tax period is generally a calendar month, but a calendar year for certain tax objects such as exceeding borrowing costs.

Tax returns

The combined CIT and payroll tax return (form "TSD" with appendices) must be submitted to the local tax authorities by the tenth day of the month following a taxable distribution or payment. Tax returns may be filed electronically.

Payment of tax

CIT and payroll taxes must be remitted to the local tax authorities by the tenth day of the month following a taxable distribution or payment. No advance CIT payments are required.

Advance rulings

The aim of the advance ruling system is to provide certainty on the tax consequences of specific transactions or combination of transactions taking place in the future. The ruling is binding on the authorities (and not on the taxpayer) if the transaction was made within the deadline and the description provided in the ruling and the underlying legislation has not been substantially changed in the meantime. Estonian legislation specifically excludes obtaining rulings when the interpretation of the legislation is objectively clear, the situation is hypothetical, or the main purpose of the planned transaction is tax avoidance. In addition, transfer pricing valuation issues are excluded from the scope of the binding ruling system.

Tax audit process

There is no statutory tax audit cycle in Estonia.

Statute of limitations

As a general rule, the statute of limitations is three years. In case of intentional tax evasion, it is five years.

Topics of focus for tax authorities

The main topics of focus for tax authorities are 'envelope wages', personal services companies, VAT fraud, and transfer pricing.