Dear Community!
As you wrote it seems good, but the details matter, so I have asked directly the estonian tax office about DTT romanian corporatioin dividend to estonian resident taxation. This is what I got:
"Regarding to the Art 10 of the tax treaty between
Romania and Estonia Romania can charge until 10 per cent of the gross amount of the
dividends.
Income tax shall not be charged in Estonia on dividends if income tax has been paid on the share of profit on the basis of which the dividends are paid or if income tax on the dividends has been withheld in a foreign state."
I am not sure, but tell me if I am wrong. It says to me, if there is WHT in Romania on dividend, then there is
no tax on that in Estonia. Is that true?
What about if there is no WHT in Romania, bc the romanian company just pay the microenterprise tax (3-1%), but pay dividend without any other tax, bc there is an option for that:
"For example, the distribution of bonuses in the amount to the share of each contributor is not subject to the dividend tax. The same thing is available for the distribution of dividends made in
cash or kind in the case of share capital reduction, as established by the company owners and contributors." In this case dividend taxed in romania or not? It means, does it taxable on personal level at estonia or not?
What do you think? Do you see any option?
Do you recommend any other company instead of romanian one to make it low taxes with estonian residency?
Happy hunting for best low tax structure!