Estonian Company Run from the Philippines: Tax Rules

Many people living in the Philippines form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from the Philippines. The Philippine National Internal Revenue Code decides a company's status by where it was created: a corporation created or organised in the Philippines is domestic, any other is foreign. A foreign corporation engaged in trade or business in the Philippines is a resident foreign corporation and pays tax on its Philippine-source income. On the owner side, a Filipino citizen living in the Philippines is taxed on income from everywhere, while a foreign individual is taxed only on Philippine-source income. And there is no tax treaty between Estonia and the Philippines. 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 Philippine tax adviser before you form or buy the company. We read Title II of the National Internal Revenue Code of 1997, as amended, in the text published by the Bureau of Internal Revenue on bir.gov.ph, on 22 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 the Philippines: the company side

Domestic or foreign by creation. A domestic corporation is one created or organised in the Philippines or under its laws; a foreign corporation is one that is not domestic (National Internal Revenue Code, Section 22(C) and (D)).
Trade or business in the Philippines. A foreign corporation engaged in trade or business within the Philippines is a resident foreign corporation; one not so engaged is a nonresident foreign corporation (Section 22(H) and (I)).
Philippine-source income only. A domestic corporation is taxed on income from sources within and without the Philippines; a foreign corporation, whether engaged in trade or business in the Philippines or not, only on income from sources within the Philippines (Section 23(E) and (F)).
The rate. A resident foreign corporation pays income tax of 25 percent of its taxable income from sources within the Philippines (Section 28(A)(1)).

An OÜ is created under Estonian law, so for the Code it is a foreign corporation. If you do its work from the Philippines, whether it is engaged in trade or business there, and which of its income is from Philippine sources, is the question these sections raise. Your Philippine tax adviser answers it with the facts of your case.

In the Philippines: the owner side

Filipino citizens living in the Philippines. A citizen of the Philippines residing there is taxable on all income derived from sources within and without the Philippines (Section 23(A)).
Foreign individuals. A resident alien is an individual whose residence is within the Philippines and who is not a citizen (Section 22(F)); an alien individual, resident or not, is taxable only on income from sources within the Philippines (Section 23(D)).

The Code's Title II has no controlled foreign company rule; we found none in the text we read. How a dividend or a board fee from the Estonian company is taxed in your hands in the Philippines is a question for your Philippine tax adviser.

No tax treaty between Estonia and the Philippines

The Philippines is not on the list of Estonia's tax treaties published by the Estonian Ministry of Finance. So no treaty decides which country a company resident in both is resident of, and no treaty limits the tax either country charges on dividends or board fees. Each country applies its own law; whether and how double taxation is relieved then depends on each country's domestic rules — a question for your Philippine tax adviser. We do not give that ruling.

What to decide before you form or buy the company

Where the business is carried on. Trade or business in the Philippines makes the OÜ a resident foreign corporation under Section 22(H).
Who you are for the Code. A Filipino citizen living in the Philippines and a foreign resident are taxed on different income under Section 23.
How you take money out. A dividend and a board fee are different kinds of income for both countries.

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. Philippine tax returns and Philippine 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; Philippine 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 the Philippines if I run it from the Philippines?

It can be. The Philippines decides a corporation's status by where it was created, so an OÜ is a foreign corporation (National Internal Revenue Code, Section 22(C) and (D)); but a foreign corporation engaged in trade or business in the Philippines is a resident foreign corporation and pays 25 percent tax on its Philippine-source income (Sections 22(H) and 28(A)(1)). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). A Filipino citizen living in the Philippines is taxed on income from everywhere, a foreign individual only on Philippine-source income (Section 23). There is no tax treaty between Estonia and the Philippines. Ask a Philippine tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from the Philippines: what is taxed where