Jurisdictions › Estonia
Enacted

Estonia Pillar Two

Europe

Effective
Jan 2024
IIR local name
IIR
QDMTT local name
QDMTT
IIR
IIR
Enacted
UTPR
Not adopted
✕ Not adopted
QDMTT
QDMTT
Enacted
In development — This profile is provided for reference only and may contain inaccuracies. Always verify against official legislation and current OECD guidance.
Key implementation point

Estonia's distribution-based CIT system (no annual profit tax) creates near-zero covered taxes under GloBE — specific QDMTT enacted to address this.

Implementation detail
  • 01 Estonia's unique CIT regime: corporate tax is only due on distribution (no annual profit tax until dividend/deemed dividend).
  • 02 This creates a fundamental GloBE tension: Estonia collects no annual corporate tax, resulting in near-zero covered taxes and a sub-15% ETR.
  • 03 Estonia enacted a specific QDMTT to top up to 15% on undistributed profits of in-scope entities — a major departure from Estonian tax policy tradition.
  • 04 EMTA (Estonian Tax and Customs Board) issued detailed guidance on how the distribution-based model interacts with GloBE.
Enacted legislation Täiendava maksumääraga maksustamise seadus
Official sources & further reading
Track Estonia rules against your live MNE

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