Am I missing something? It seems that Estonian PE turns any company into zero-tax (until profits are distributed obviously).
i.e. UAE company is run by EE holding/resident, with PE in EE, so in UAE no tax is owed until distributed? (otherwise 9% would apply?).
Can some DTTs ruin this? This is purely about CIT now.
Taxation of the profit of a permanent establishment | Estonian Tax and Customs Board
A non-resident’s permanent establishment in Estonia pays income tax on profit and assets both in monetary or non-monetary form taken out of the permanent establishment. Specificities arising from tax treaties are taken into account in taxation.
www.emta.ee
A non-resident’s permanent establishment in Estonia pays income tax on profit and assets both in monetary or non-monetary form taken out of the permanent establishment.
i.e. UAE company is run by EE holding/resident, with PE in EE, so in UAE no tax is owed until distributed? (otherwise 9% would apply?).
Can some DTTs ruin this? This is purely about CIT now.