An Estonian private limited company (OÜ) is resident in Estonia because it is established under Estonian law. But when its owners or directors live abroad, the country where they live may also count the company as its own resident, or treat an office or a place of management there as a permanent establishment. Our series of country guides shows how this works in more than forty countries. When you need the answer for your own company, we prepare a written analysis of the rules and of your facts.
The analysis is not tax advice and not a ruling. The tax authorities decide on residence and tax, and the analysis does not replace a tax adviser in the other country; it prepares the facts and the questions you take to them.
Why residence and permanent establishment matter
- In Estonia a company established under Estonian law is resident for tax purposes (Income Tax Act § 6), and its profit is taxed when it is distributed — the guide how Estonia taxes company profit explains the rule.
- In the other country the rule is often different: many countries count as resident a company whose place of effective management, actual management body or management and control is there; others look only at where it was incorporated.
- A permanent establishment — an office, a place of management or another fixed place of business abroad — can make part of the profit taxable in that country.
- The tax treaty between Estonia and that country decides how a double residence is settled — by the place of incorporation, by the place of effective management or by an agreement of the two tax authorities — and how dividends and board fees are taxed.
What the analysis contains
- the Estonian residence rule and what it means for your company;
- the residence and permanent-establishment rules of the other country, read from their official text, with the article numbers;
- the rules of the tax treaty on residence, permanent establishment, dividends and directors' fees, and whether the treaty is in force;
- the facts of your case that the rules turn on — where decisions are taken, where the work is done, who holds the shares — and the documents that show them;
- the questions to take to a tax adviser in the other country.
What it does not contain
- tax advice, tax planning or a recommendation on how to arrange your affairs;
- tax returns, and representation before a tax authority;
- a promise of any decision of a tax authority.
How it works
- You order the analysis online and describe where the company is managed, where the work is done and who owns it.
- We read the official texts of the country concerned and the tax treaty, and write the analysis in English.
- The starting price is for one company and one other country: from €1,200. If the case needs more work — several countries or a group of companies — we tell you before the work starts.
The country guides are free to read: Estonian company run from abroad compares the rules side by side.
Prices exclude VAT. All communication takes place by email.
Ready to start? A written analysis of tax residence and permanent establishment for one company and one other country; not tax advice. 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.