Estonia–MNE Tax

Estonia

Estonian transfer pricing changes aimed to harmonize with OECD practice, leave open questions

April 12, 2022

Ricardo Schmitz, Mykolas Romeris University, discusses new amendments to the Estonian transfer pricing rules, in force since January 1, with the goal of harmonizing domestic legislation with current OECD recommendations.

Estonia

EU finance ministers fail to unanimously agree on proposed Pillar Two directive; the date on which member states would make it effective had been moved from Jan. 2023 to Dec. 2023 in compromise text; the UTPR is delayed to Dec. 2024 under this compromise; Estonia, Malta, Poland, and Sweden still have reservations; will try again Apr. 5: János Ammann / EURACTIV→

March 15, 2022

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

February 28, 2022

Austria

EU’s path forward on global minimum tax is under debate

January 18, 2022

EU member states are at odds on various issues related to the directive to implement within the EU the global minimum tax portion of the OECD agreement, with several members expressing concerns about key aspects in a January 17 Economic and Financial Affairs Council . . .

Estonia

Estonia’s support for OECD tax deal is conditioned on ensuring that EU implementing rules affect only large in-scope multinationals and ‘leave the rest of our existing system untouched,’ Finance Minister says: Estonian government→

December 1, 2021

Asia-Pacific

Mauritania becomes 141st country to join global tax ‘Inclusive Framework’

November 4, 2021

The OECD Inclusive Framework gains another member, with the northwestern Africa country of Mauritania joining as the 141st member, according to a November 4 OECD release. Mauritania is also joining the October 8 global tax pact.

Estonia

Estonia’s joining global tax deal may mean some companies will look elsewhere, but there will be no mass exodus, and Estonian companies could have been worse off outside deal, Finance Ministry predicts: Baltic Times→

October 19, 2021

Africa

Global tax talks reach ‘critical mass’ for landmark deal by tweaking details

October 8, 2021

The historic October 8 agreement on a global minimum tax and new rules for allocating taxing rights for large multinationals both firms up issues left open in the initial July statement and reflects concessions that were made to bring into the deal a few new countries, including . . .

Americas

Switzerland, Estonia, Ireland seek concessions in global tax deal

October 4, 2021

OECD Secretary-General Mathias Cormann told the Swiss Finance Minister that he personally does not see a consensus on a global minimum tax at a rate above 15%, attempting to allay Swiss concerns about the Inclusive Framework’s July statement referring to . . .

Africa

Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal

September 30, 2021

Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .

Estonia

EU state of the union address calls for tax reforms

September 17, 2021

European Commission President Ursula von der Leyen stressed the importance of fair taxation and initiatives to expand the tax base in her 2021 state of the union address on September 15, emphasizing . . .

Estonia

Two minimum taxes: US eyes robust rate, while small countries seek carve-outs

September 8, 2021

The US should raise the minimum tax on corporate foreign earnings to 21% while the OECD works towards a 15% floor on tax competition, according to a September 7 article from two US Treasury officials . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Estonia

Greece, Hungary, Iceland fall short of tax dispute resolution goals, OECD review finds

May 26, 2021

Iceland has no bilateral advance pricing agreement (APA) program in place, and Greece, Hungary, and the Slovak Republic are failing to timely resolve mutual agreement procedure (MAP) cases, according . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Estonia

Estonia joins BEPS multilateral tax treaty

January 19, 2021

Estonia deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Asia-Pacific

Hong Kong announces entry into force of Cambodia, Estonia tax treaties

December 30, 2019

The Hong Kong government on December 27 announced that new tax treaties with Cambodia . . .

Digital Economy

Estonia won’t enact a digital tax, minister says: ERR→

December 30, 2019

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Asia-Pacific

Hong Kong signs tax treaty with Estonia

September 26, 2019

The Hong Kong government today announced that Hong Kong and Estonia have signed a . . .

Asia-Pacific

Japan, Estonia sign tax treaty

August 30, 2017

The governments of Japan and Estonia today signed a tax treaty, Japan’s Ministry of Finance has reported. The new treaty . . .

Asia-Pacific

OECD asks for taxpayer feedback on cross-border tax dispute resolution procedures in Estonia, Greece, Hungary, Iceland, Romania, Slovak Republic, Slovenia and Turkey

March 12, 2018

The OECD today asked taxpayers to provide feedback on their experiences with cross-border tax dispute resolution procedures in the following countries: Estonia, Greece, Hungary, Iceland, Romania, Slovak Republic, Slovenia . . .

Estonia

Estonian corporate tax reform includes reduced tax rate for dividend payments: EY→

June 28, 2017

Estonia

Ireland-Estonia treaty now exempts some royalty payments from tax

May 4, 2016

The tax treatment of royalty payments under the Ireland-Estonia tax treaty has been revised on account of the treaty’s most favored nation clause, Irish . . .

Americas

Kazakhstan, Peru, UAE sign BEPS MLI addressing tax avoidance by multinationals

June 27, 2018

Kazakhstan, Peru, and the UAE today signed the BEPS multilateral tax instrument (MLI), bringing the total number of signatories to the treaty to 79 and the number of covered jurisdictions to 81, the OECD has announced. Also, Estonia has . . .

Americas

OECD publishes updated transfer pricing profiles for 14 countries

April 9, 2018

The OECD today published transfer pricing profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay. The profiles

Asia-Pacific

Japan-Austria tax treaty negotiations commence

October 3, 2016

The governments Japan and Austria will negotiate amendments to their 50+ year old tax treaty, Japan’s. . .

Americas

US to exchange country-by-country reports with Australia, Estonia

August 3, 2017

The US IRS today announced that it has entered into separate agreements with Australia and Estonia to exchange country-by-country reports . . .

Asia-Pacific

Japan and Estonia to negotiate tax treaty

August 8, 2016

Japan and Estonia will begin negotiations for a tax treaty, Japan’s Ministry of Finance announced . . .

Asia-Pacific

Japan to sign tax treaties with Denmark and Estonia

May 15, 2017

Japan’s Ministry of Finance today announced that it has reached agreements in principle for tax treaties . . .

Asia-Pacific

Japan’s tax treaties with Estonia and Lithuania enter into force

August 31, 2018

Japan’s Ministry of Finance today announced the entry into force of tax treaties signed with Estonia and Lithuania as . . .

Australia

31 nations sign agreement on exchange of country-by-country transfer pricing reports

January 27, 2016

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .

Estonia

Estonian bill would reduce tax rate on profit distributions, tax long-term intragroup loans: EY→

April 27, 2017

Estonia

UK ratifies, Estonia signs OECD multilateral instrument on tax avoidance

July 2, 2018

The OECD announced June 29 that the UK has ratified and Estonia has signed a multilateral tax treaty designed to curtail tax avoidance by multinational . . .

Africa

Luxembourg announces new tax treaty with Serbia; entry into force of protocols with Ireland, Mauritius, Lithuania and UAE; and law approving tax treaties with six other nations

December 31, 2015

The government of Luxembourg has announced that protocols signed with Ireland, Mauritius, Lithuania and United Arab Emirates entered into force on December 11 and . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin