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Draft Estonian Legislation Published to Encourage Profit Distributions and Discourage Hidden Distributions through Loans

21 April 2017

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Proposed Changes

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Estonia

The Estonian Ministry of Finance has announced draft legislation meant to encourage regular profit distributions and discourage hidden distributions through loans made by Estonian subsidiaries to foreign parents. Regarding profit distributions, the legislation introduces a reduced tax rate of 14% on distributions up to the average distribution amount in the previous three years, with the excess subject to the standard 20% rate. Regarding hidden distributions, the legislation provides for 20% tax deposit on loans exceeding the subsidiaries paid-in capital and loans received, with the deposit becoming a final tax if the loan is not repaid within two years ({News-2017-03-13/P/2- previous...