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
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