Estonian Company Run from Finland: Tax Residence

Many Finnish entrepreneurs buy or form an Estonian private limited company (OÜ) and run it from Finland. That works, but it has a tax question that Finnish owners must answer before they start: since 2021, Finnish law can treat a company registered abroad as a Finnish company for tax purposes when it is managed from Finland. This guide sets out the rules in both countries with their sources, what they mean for an owner and board living in Finland, and what we do on the Estonian side.

The guide is general information, not tax advice. Whether your company is taxed in Finland depends on the facts of your case; ask a Finnish tax adviser before you buy or form the company. The Finnish Income Tax Act (tuloverolaki) was read in Finlex, the official database, on 16 October 2026.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Finland: where the company is managed

The rule. A company established or registered abroad whose place of effective management (tosiasiallinen johtopaikka) is in Finland is generally liable to tax in Finland on its income from Finland and from elsewhere (tuloverolaki 9 § 1 momentti 1 kohta, in force since 1 January 2021).
Where management is. The place of effective management is where the board or another decision-making body makes the company's most important decisions on its top-level day-to-day management; other circumstances of the company's organisation and business are also taken into account (9 § 8 momentti).
The consequence. Such a company is taxed under the rules for Finnish companies (9 § 9 momentti).
A fixed place of business. Even when the company is not resident in Finland, income that belongs to a permanent establishment in Finland (kiinteä toimipaikka) is taxed in Finland (9 § 3 momentti).

An OÜ whose only board members live in Finland and run the business from there is therefore exactly the case these rules look at. Whether the company is in fact managed from Finland is a question of fact, assessed by the Finnish Tax Administration.

When both countries count the company as resident

If the company is resident under Estonian law and under Finnish law at the same time, the tax treaty between Finland and Estonia of 23 March 1993 (Finnish treaty series SopS 95–96/1993, amended by SopS 37/2004 and 55/2016) decides how it is treated, together with the multilateral convention on tax treaty measures (MLI), which entered into force for Estonia on 1 May 2021. How the treaty settles a particular company's case is a question for the two tax administrations and for your Finnish tax adviser — we do not give that ruling.

What to decide before you buy or form the company

Who manages the company, and where. The board's composition and where its decisions are made are the facts the Finnish rule looks at.
Where the work is done. Work done in Finland through a fixed place of business can create a permanent establishment there.
Ask first. A Finnish tax adviser can assess your plan; the Finnish Tax Administration also gives advance rulings.

What we do on the Estonian side

a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included., or with a VAT number — €1,450;
a new company formed remotely by power of attorney — €1,250 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.

Our accounting covers the Estonian company's Estonian obligations. Finnish tax returns and Finnish tax advice are not included. The same question for owners in Germany, Poland, Spain and Italy. The purchase itself is described in the guide ready-made company in Estonia; this guide is also in Finnish.

Prices exclude VAT. All communication takes place by email.

Ready to start? Remote purchase by notarised power of attorney — the Estonian side; Finnish tax advice 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

Is my Estonian company taxed in Finland if I run it from Finland?

It can be. Since 2021 a company registered abroad whose place of effective management is in Finland is generally liable to tax in Finland (Finnish Income Tax Act 9 §); that is where the board makes its most important day-to-day management decisions. In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). When both countries count it as resident, the Finland–Estonia tax treaty decides. Ask a Finnish tax adviser before you buy or form the company; we handle the Estonian side, not Finnish taxes.

Estonian company run from Finland: where it is taxed