Estonian Company Run from Slovakia: Tax Rules

Many Slovak entrepreneurs form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Slovakia. Slovak income tax looks first at where the company is managed: a legal person with its seat or its place of effective management in Slovakia is taxed there on its worldwide income. The controlled foreign company rule of the Slovak Income Tax Act names Slovak legal persons as the controlling owner. And the Estonia–Slovakia tax treaty leaves a company resident in both countries to an agreement between the two tax authorities. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Slovak tax adviser (daňový poradca) before you form or buy the company. We read the Income Tax Act (zákon č. 595/2003 Z. z. o dani z príjmov, version in force from 1 January 2026) on the official legal portal of the Slovak Republic, slov-lex.sk, and the Estonia–Slovakia tax treaty in Riigi Teataja, on 22 October 2026; the English wording of the Slovak act below is our translation.

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 Slovakia: the company side

Seat or place of effective management. A taxpayer with unlimited tax liability is a legal person that has its seat or its place of effective management in the territory of the Slovak Republic. The place of effective management is the place where the essential management decisions and business decisions for the legal person as a whole are made or taken, even if its address is not entered in the commercial register (Income Tax Act, § 2(d), point 2).
The treaty decides first. A legal person that is treated as resident in the other country under an international treaty is a taxpayer with limited tax liability in Slovakia (§ 2(e), point 3).
Registration. A legal person must apply to the tax administrator for registration by the end of the calendar month after the month in which it acquired a place of effective management in Slovakia (§ 49a(8)).

An Estonian OÜ has its seat in Estonia. If you live in Slovakia and take the essential management and business decisions there, its place of effective management can be in Slovakia — and then Slovakia treats it as a Slovak taxpayer, unless the treaty settles its residence for Estonia. Your Slovak tax adviser answers that with the facts of your case.

In Slovakia: the owner side

Controlled foreign company. A legal person with its seat abroad is a controlled foreign company of a Slovak legal person (a taxpayer under § 2(d), point 2) that, alone or with related persons, holds more than 50% of its capital, of its voting rights or of its profits, if the foreign corporate income tax it pays is lower than the difference between the tax computed under the Slovak act and that foreign tax (Income Tax Act, § 17h(1)).
Who is the controlling owner. The rule names only taxpayers under § 2(d), point 2 — legal persons. An individual living in Slovakia who owns the OÜ is not named in it; how the individual's own income from the company is taxed is a question for your Slovak tax adviser.

The Estonia–Slovakia tax treaty

A company resident in both countries. The competent authorities shall endeavour to settle the question by mutual agreement and determine how the Convention applies to it; in the absence of agreement, it is not considered a resident of either country for the benefits of the Convention (Convention signed in Bratislava on 21 October 2003, Article 4(3)).
Dividends. The country of the paying company may tax dividends at no more than 10 per cent of the gross amount when the beneficial owner is resident in the other country (Article 10(2)).
Directors' fees. Fees for a member of the board of a company resident in the other country may be taxed in that country (Article 16).

Whether the Multilateral Instrument changes these articles is a question for your Slovak tax adviser. We do not give that ruling.

What to decide before you form or buy the company

Where the essential decisions are taken. This is the fact the Slovak rule on the place of effective management looks at.
Who owns the company. A Slovak company holding more than 50% brings in the controlled foreign company rule.
How profits reach you. Dividends and board fees are covered by Articles 10 and 16 of the treaty.

What we do on the Estonian side

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.

Our accounting covers the Estonian company's Estonian obligations. Slovak tax returns and Slovak tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

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; Slovak 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 Slovakia if I run it from Slovakia?

It can be. Slovakia taxes a legal person that has its seat or its place of effective management in Slovakia — where the essential management and business decisions for the company as a whole are taken (Income Tax Act 595/2003, § 2(d), point 2). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Under the Estonia–Slovakia tax treaty, the two tax authorities try to settle the residence of a company resident in both by mutual agreement; without agreement it gets no treaty benefits (Article 4(3)). The Slovak controlled foreign company rule names Slovak legal persons as the controlling owner (§ 17h). Ask a Slovak tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Slovakia: what is taxed where