An Estonian private limited company (OÜ) can be owned and run from anywhere, and many e-residents do exactly that. In Estonia the company stays Estonian: a company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6), and its profit is taxed when it is distributed. But the country where you live can have its own rule — many tax a foreign company as their own when it is managed from there. This page compares the rules of the countries our guides cover, each with its official source.
The page is general information, not tax advice. Ask a tax adviser in your country before you form or buy the company.
The rule in five countries
| Country | When the country counts the company as its own | Source |
|---|---|---|
| Finland | its place of effective management is in Finland — where the board takes the most important day-to-day management decisions | tuloverolaki 9 § 1 momentti 1 kohta and 8 momentti |
| Germany | its place of management (Geschäftsleitung) is in Germany — the centre of its top-level business direction | Körperschaftsteuergesetz § 1(1) no. 1; Abgabenordnung § 10 |
| Poland | its management (zarząd) is in Poland — its current affairs are run there in an organised and continuous way | Corporate Income Tax Act art. 3(1) and (1a) |
| Spain | its place of effective management is in Spain — where the direction and control of all its activities lie | Ley 27/2014, article 8(1) |
| Italy | for most of the tax period its strategic decisions are taken, or its day-to-day management is carried out mainly, in Italy | TUIR article 73(3) |
When both Estonia and the other country count the company as resident, the tax treaty between them decides. The treaties do not all use the same rule — for example, the Poland–Estonia treaty treats such a company as resident where its status derives from, while the Spain–Estonia treaty, as modified by the multilateral convention, leaves it to the two tax administrations. Each country guide explains its treaty as far as we could read the official text.
A permanent establishment
Even when the company is not resident in the other country, an office or other fixed place of business there — including a place of management — can be a permanent establishment, and the profit that belongs to it can be taxed there. The country guides cite the rule of each country and treaty.
Another country
If you live elsewhere, the same question applies: does your country tax a foreign company that is managed from there, and what does its treaty with Estonia say? A tax adviser in your country answers it. Our guide how Estonia taxes company profit covers the Estonian side.
What we do
We form and sell Estonian companies and keep their Estonian side in order:
- online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
- a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
- accounting — from €150 / month and the annual report — from €450;
- the registered address and contact person after the first 12 months — €350 / year.
Tax returns and tax advice in other countries are not included.
Prices exclude VAT. All communication takes place by email.
Ready to start? A new Estonian company — online for e-residents or by power of attorney; tax advice in other countries is not included. Order.
Official sources
The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.
- Income Tax Act — Riigi Teataja, English translation
Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.
Frequently asked questions
Where does my Estonian company pay tax if I live abroad?
In Estonia, because it was established under Estonian law (Income Tax Act § 6); there its profit is taxed when it is distributed. But the country you live in may also count the company as its own when it is managed from there — Finland, Germany, Poland, Spain and Italy do, each by its own rule. When both countries count it as resident, their tax treaty decides. Our comparison page shows the five rules with their sources; ask a tax adviser in your country before you start.
Related guides
- Ready-made Estonian company with EU VAT
- Why buy a ready-made company in Estonia
- After buying an Estonian company: the first steps
- Estonian company (OÜ) or UK Ltd: the official facts compared
More on this topic: Company formation.