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ESTONIAN TAXES AND
TAX STRUCTURE


Tax Policy Department
Revised in 2012
Population      (01.01.2012)     1,339,662
Total area                       45,227 km2
Average salary (2010)            792 EUR
                (2011 IV quarter)        865 EUR
Currency                         EUR
GDP (2011)                       15,973 mill EUR
Economic growth          (forecast for 2012)       1.7%
                                 (forecast for 2013)      3.0%
GDP per capita (2011)            11,918 EUR
Inflation (forecast for 2012)    3.3%
Outline of the presentation
• The main principles of the Estonian tax system,
  the current tax structure
• Taxation Act
• Direct Taxes
   – Reasons for introduction of the flat rate in Estonia
   – The outcome of the reform
   – Personal Income Tax
   – Corporate Income Tax
   – Social Tax
• Indirect taxes
   – VAT
   – Excise duties
   – Gambling tax
• Plans for the future
Estonian Tax System

The main principles of Estonian tax policy:
• simple tax system
• broad tax base, low rates

Estonia is a European pioneer in income taxation:
• Flat income tax rate since 1994 (followed by
  Lithuania, Latvia, Russia, Ukraine, Serbia,
  Slovakia, Georgia, Romania, ..)
• Unique corporate tax system since 2000
Taxation Act




5
Estonian Tax System

• To achieve sustainable, socially and regionally
  balanced economic growth Estonian tax
  system consists of state taxes provided and
  imposed by tax acts and local taxes imposed by
  a rural municipality or city council in its
  administrative territory pursuant to law
State taxes

1) excise duties;
2) income taxes;
3) gambling tax;
4) value added tax;
5) land tax;
6) social tax;
7) customs duty;
8) heavy goods vehicle tax.
Local taxes


 1) advertisement tax;
 2) road and street closure tax;
 3) motor vehicle tax;
 4) animal tax;
 5) entertainment tax;
 6) parking charge.
Taxation Act
• Taxation act specifies
   – Estonian tax system
   – main definitions used in all tax acts
   – requirements for tax acts
   – rights, duties and liability of taxpayers,
     withholding agents, guarantors and tax
     authorities
   – regulations of the tax procedure and
     procedure for resolution of tax disputes
   – penalty interest rate 0,06% per day
Taxation Act
“Tax” is
• a single or periodical financial obligation
• imposed by an Act or by a local government
  council regulation according to Local Taxes Act
• for the performance of the public law functions
  or to obtain revenue to perform these functions
• subject to performance pursuant to the
  procedure, in the amount and on the due dates
  prescribed by an Act
• collected without direct compensation therefore.
Taxation Act
Requirements for Act concerning tax
1) name of the tax;
2) object of taxation;
3) tax rate;
4) taxpayer;
5) recipient of or place of receipt of the tax;
6) due date or term for payment of the tax;
7) procedure for payment of the tax;
8) procedure for implementation of the Act
   concerning a tax;
9) possible tax incentives.
Tax authority

• The tax authority for state taxes is the Tax
  and Customs Board with its regional
  offices. The tax authority operates within the
  area of government of the Ministry of Finance.

• Tax authority verifies the correctness of tax
  payments, assesses amounts of tax and
  interest due in the cases provided by law,
  collects tax arrears and implements sanctions
  against persons who violate tax Acts.
Main tax rates

• Corporate income tax – 21% on distributed profit
• Personal income tax – 21%
• Social tax – 33% (payable by employer)
• Unemployment insurance payment – 2,8 %
  payable by employee and 1,4% payable by
  employer
• Contribution to the mandatory funded pension
  system - 2% (payable by employee)
• Value added tax - 20% (standard rate), 9%
  (reduced rate)
Tax structure
Structure of tax burden (% of GDP)




                  Source: Statistical Office of Estonia, Ministry of Finance
Structure of general government tax revenue




                   Source: Statistical Office of Estonia, Ministry of Finance
Tax burden ( % of GDP)




                 Source: Statistical Office of Estonia, Ministry of Finance
State Budget Tax Revenue 2011
  Total tax revenue   4,342.1 million EUR
  Total revenue       5,872.2 million EUR




                                            Source: Ministry of Finance
Tax Revenue 2011, million € (collected)
    State taxes                                            4 342,1
     Direct taxes                                          3 093,8
      Personal income tax*                                    845,9
      Corporate income tax                                    201,1
      Social tax                                            1 801,4
      Unemployment insurance                                  194,0
      Land tax                                                 51,5
     Indirect taxes                                         2 112,3
      VAT                                                  1 343,3
      Excise duties                                           717,0
      Heavy vehicle tax                                         3,7
      Customs tax                                              29,1
      Gambling tax                                             19,3
    Local taxes                                                25,5
* - The amount received by the state + local governments        Source: Ministry of Finance
Direct taxes
Direct taxes


•   Personal income tax
•   Corporate income tax
•   Social tax
•   Land tax
Reasons for introducing flat
     rate in Estonia
Reasons for introducing flat rate in Estonia

• High inflation rate - in case of flat rate there
  is no need of frequent adjustment of tax
  brackets
• Flat rate system is easier to administer (for
  both taxpayers and tax administrators)
• More transparency

The new law entered into force on January
 1st 1994.
The outcome…
Personal income tax revenue 1994-2016
                                                               million €




                   Source: Statistical Office of Estonia, Ministry of Finance
Corporate income tax revenue
                                                                            million €




* - includes revenue under the prior Income Tax Act (taxable period 1999)
Personal income tax
Personal income tax

• Residents pay tax on their total worldwide
  income.
• Non-residents pay tax only on their income
  received from Estonian sources.

• Individuals are Estonian residents if they:
     - have a permanent home in Estonia, or
     - stay in Estonia 183 days or more during
     any 12-month period.
Income Tax Act
Period of taxation: a calendar year

Tax rate: 21% (separate tax rate 10% for certain pensions
  and payments to non-residents)

Decrease of the income tax            rate   (both   for
 individuals and legal persons):
  Until the year 2004 – 26%
  Income of the year 2005 – 24%
  Income of the year 2006 – 23%
  Income of the year 2007 – 22%
  Since 2008 – 21%
Income Tax Act
Non-taxable minimum (annual basic exemption): 1728 EUR

Additional exemption for state pensions:    2304 EUR
  for calendar year

Increase of the non-taxable minimum (per year):
   Income of the year 2003 –        12 000 EEK (767 EUR)
   Income of the year 2004 –        16 800 EEK (1074 EUR)
   Income of the year 2005 –        20 400 EEK (1304 EUR)
   Income of the years 2006- 2007 – 24 000 EEK (1534 EUR)
   Income of the years 2008- 2010 – 27 000 EEK (1726 EUR)
   Since 2011 - 1728 EUR
Income tax reduction
Personal income tax
For non-residents there is a limited list of taxable income in the
 Income Tax Act:

• income from work under a labour contract or contractor's
  agreement in Estonia;
• income from a business carried on in Estonia;
• interest income received from Estonia (only if it is substantially
  higher than that on similar debt claims);
• royalties;
• income from the lease of assets located in Estonia;
• gains from disposal of assets located in Estonia;
• directors' fees paid by Estonian enterprises;
• income of a sportsman or an artist from his activities in Estonia
• pensions and scholarships.
Personal income tax

For non-resident natural persons
• Period of taxation is a calendar year
• Tax rates: 21% and 10%

• Estonia has 49 treaties for the avoidance of
double taxation (income tax and capital
taxes) in force
Personal income tax
Tax allocation of personal income tax paid by
residents

• The amount received by local governments is 11.4 % of
 taxable income (deductions are not taken into account),
 the excess amount is received by the state

• Income tax paid on pensions and capital gain is
 received by the state

Non-residents:
• income tax is received by the state
Personal income tax

Avoidance of double taxation

Natural persons

• Exemption method for foreign dividends and
  certain salary income

• Credit method for all other types of foreign
  income
Corporate income tax
Corporate income tax

• Corporate tax reform in year 2000

• The ultimate goal of the reform was
  promotion of business and acceleration of
  economic growth by making additional funds
  available for investment
Corporate income tax


                      Additional
                   funds available
                    for investment

                                      Stricter
  Transparency
                                     regulation
  and exchange
                                     of transfer
  of information
                                       pricing

                   Acceleration
                   of economic
                      growth
    Elimination                      Introduction
    of technical                      of the CFC
   shortcomings                          rules
Corporate income tax

The moment of taxation of corporate income is
  postponed until the distribution of the profits


The system applies to:
   • Estonian resident companies
       - legal persons that are established pursuant to
         Estonian law
   • permanent establishments (PE) of non-resident
     companies
     - PE is an entity through which the business of a
     non-resident is carried out in Estonia
Corporate income tax
The taxation of profit until 1999
                    Tax rate 26 %
                      (on gross     Income tax
                        profit)       26 EUR


        Profit
       earned                                    Dividend
      100 EUR                                    payment
                                                 74 EUR



                                    Time
Corporate income tax
 Corporate income tax
 The timing of tax payment under the new system (since 2000)*
 The tax rate has been decreased since 2005


                                                                Income tax
                            No tax                                26 EUR


        Profit                                                      Tax rate 26/74
                                                                   (on net amount,
       earned                                Dividend              equals to 26% of
                                                                     gross profit)
      100 EUR                                payment
                                             74 EUR


                                    Time
Corporate income tax


• Tax rate in 2012: 21% (21/79 of the net amount)

• Period of taxation: a calendar month
Corporate income tax
Tax base
  • corporate profits distributed in the tax period;
    dividends and other profit distributions, incl.
    liquidation proceeds and payments made on reduction
    of company’s equity or redemption or return of shares
  • taxable gifts, donations and representation expenses;
  • expenses and payments unrelated to business.

Fringe benefits are taxable at the level of employer.

Losses – taken into account (the Estonian Commercial Code
  does not allow to distribute profits if the company has
  losses from previous years)
Corporate income tax
Profit earned                                                                  Gifts
  in 2009                                                                       100 EUR         CIT (21/79) 27
200 EUR +                                                                       Expenses
                                                                               unrelated to    CIT (21/79) 80
Profit earned   1400 EUR potentially taxable income
                                                                                business
  on 2010                                                                                                              Total CIT
                                                                                 300 EUR
                                                                                                                       liability 294
                                                      Tax liability deferred
 1000 EUR                                                                                      CIT (21/79) 53
                                                                               Donations
 + qualified                                                                   200 EUR
  dividend
                                                                               Dividend /         Exemption
  received
                                                                               liquidation     method  Taxable             Credit
  100 EUR                                                                        640 EUR           amount                  method
  + foreign                                                                                      640 – 100 = 540           144 – 10 = 134
   interest
                                                                                                         CIT (21/79) 144
received
  100 EUR
(source state
  WHT 10)
                                                                                              Time
Corporate income tax

There are 3 main methods introduced in the Estonian
Income Tax Act, the goal of which is to minimize the
possibilities for tax fraud and evasion

   – CFC (Controlled Foreign Corporation) rules:
     residents have to declare and pay tax on the income
     of off-shore companies under their control
   – Stricter regulations for minimising the use of
     transfer-pricing schemes
   – Withholding tax of 21% on all payments to so-called
     off-shore companies for services
Corporate income tax
Avoidance of double taxation

Companies and non-resident’s PEs

• Exemption method for qualified (threshold 10%)
  profit distributions
  the income tax will not be charged on dividends or on
  payments upon reduction of share capital or
  contributions, redemption of shares or liquidation of a
  legal person on certain conditions.

• Credit method for all other types of foreign income
Structure of declared corporate income
tax 2003-2016                        million €




                     Source: Statistical Office of Estonia, Ministry of Finance
Social tax
Social tax

Tax Base
• Employers' payments to natural persons (wage
  income) – tax payable by employers
   • in cash
   • in kind (fringe benefits)

• Business income of sole proprietors – tax
  payable by self employed persons
Social tax

Period of taxation

• Calendar month for wage income
• Calendar year for business income of sole
  proprietors
Social tax

• Tax rate is 33 % of the taxable amount


• Social tax payable is personificated and
will be taken into account in making
pension payments.
Social tax

• Tax allocation IF the person has joined the II
  pension pillar (compulsory for the persons who
  have born in 1983 or later; voluntary for older people)
        Social tax, rate 33%                   Contribution to the
     (payable by employer or self               II pillar (made by
          employed person)                          employee)

          13%             16%        4%                  2%

 State health       State pension            Personal pension
  insurance       insurance system        account of the person (II
    system            (I pillar)           pillar) 2% + 4%= 6%
Social tax revenue 1994-2016
                                                million €




                                            Source: Ministry
                               of Finance
Structure of declared social tax 2003-2016
                                                           million €




                 Source: Statistical Office of Estonia, Ministry of Finance
Indirect taxes
Indirect taxes

• Value added tax
• Alcohol excise duty
• Tobacco excise duty
• Energy products excise duty
• Packaging excise duty (budget revenues
  insignificant)
• Heavy goods vehicle tax
• Gambling Tax
Value-added tax (VAT)
VAT

Taxable person
• Person whose taxable supply (excluding
import) exceeds 16 000 EUR in a calendar
year

• Voluntary compliance possible for anyone,
who carries out economic activity in Estonia
VAT

Tax base
VAT is charged on:
  • transactions of goods and services within
  Estonia
  • intra-Community acquisitions of goods and
  services
  • importation of goods and services
  • provision of services which are taxable in
  Estonia, supplied by the foreign taxable person
VAT

Tax rates
• Standard rate is 20%.
• Reduced rate is 9% (books, newspapers,
  medicines, accommodation).
• Zero rated: export; intra-Community
  supply; vessels and aircrafts used on
  international routes, including equipment and
  fuel; goods and services for consumption
  supplied on board of vessels and aircrafts.
VAT
Exempted goods and services are:
• postal services
• health services
• social services
• insurance services
• services for the protection of children
• transportation of sick, injured or disabled
  persons
• supply of immovables
• the leasing and letting of immovables, etc.
VAT revenue 1994-2016
                                                              million €




               Source: Statistical Office of Estonia, Ministry of Finance
Excise duties
Duty rates


• Alcohol and tobacco products – all rates
  meet EU minimum levels

• Energy products – all rates meet the EU
  minimum levels except for oil shale for which
  there is a transitional period up to 2013
Excise duty rates on alcohol 01.02.2012
                               Excise duty rates in    EU minimum
                  Unit                euros             excise duty
                                                           rates
Wine and
fermented                       (up to 6 %): 33,30
                Hectolitre                                  0
beverage                          (> 6 %): 76,80
                                       5,70
Beer
              1 % alcohol in
                               (yearly production up       1,87
                hectolitre
                                 to 3000 hl): 2,85
Intermedi-
ate product     Hectolitre            164,00               45
              Hectolitre of
Other
              pure alcohol             1490                550
alcohol
Excise duty rates on tobacco products
                  01.01.2012
         Product            Excise duty rates          EU minimum
                                in euros              excise duty rates

CIGARETTES:
Specific rate                    42,18          64 EUR per 1000 cigarettes,
(1000 cigarettes)                               but not less than
Ad valorem rate                                 57 % from weighted average
( % of the retail selling         33 %          price of cigarettes
price)
CIGARS                                          12 EUR or 5% from the retail
(1000 cigars)                    191,73         selling price
CIGARILLOS                                      12 EUR or 5% from the retail
(1000 cigarillos)                191,73         selling price
SMOKING
TOBACCO                          55,79          40 EUR or 40% from the retail
(1 kg )                                         selling price
ENERGY PRODUCTS: national excise duty rates on
MOTOR FUELS and the EU minimum excise levels
 ENERGY            Excise rates in Estonia   The EU minimum levels of
 PRODUCT                 01.01.2012          taxation
 Unleaded               422,77 EUR/                  359 EUR/
 petrol                    1000 l                     1000 l
 Leaded petrol         422,77 EUR/            
                          1000 l
 Gas oil                392,92 EUR/                330 EUR 1000 l
                           1000 l

 Gas oil     for        110,95 EUR/                   21 EUR/
 specific                  1000 l                      1000 l
 purposes
 LPG                    125,26 EUR/                  125 EUR/
                          1000 kg                     1000 kg

 Petroleum              330,1 EUR/                 330 EUR 1000 l
                          1000 l
National excise duty rates applicable to heating fuels
and electricity and the EU minimum excise levels
 Energy          Excise rates in    The EU minimum levels of taxation
 product            Estonia
                  01.01.2012       business              non-business
 Light fuel      110,95 EUR/         21 EUR/                 21 EUR/
 oil                1000 l            1000 l                   1000 l
 Heavy fuel       15,01 EUR/         15 EUR/                 15 EUR/
 oil                1000 kg          1000 kg                  1000 kg

 Petroleum        330,1 EUR/
                     1000 l
                                        -                        -
 Natural          23,45 EUR/       0,15 EUR/ GJ             0,3 EUR/ GJ
 gas                1000 m3

 Coal      and   0,3 EUR/ GJ       0,15 EUR/ GJ             0,3 EUR/ GJ
 coke

 Electricity       4,47 EUR/        0,5 EUR/                  1 EUR/
                      MWh             MWh                      MWh
Excise duty revenue 1994-2016
                                                              million €




               Source: Statistical Office of Estonia, Ministry of Finance
Packaging excise duty
 Object of taxation:
   Excise duty on packaging shall be imposed on
   packaging of goods placed on the market in Estonia
   or acquired in and imported from another Member
   State of the European Union.

 Exemption from excise duty incidentally are:

 1) packaging concerning which a deposit has been
    established under the Packaging Act, except metal
    packaging of beverages, and from which at least 85
    percent of each class of packaging material is
    recovered as of 1 January 2012;
Packaging excise duty


 2) metal packaging of beverages of which of which at
    least 50 percent is recovered as of 1 January 2010;

 3) as of 1 January 2009, other packaging recovered to
    the extent provided for in § 36 of the Packaging Act.
Gambling Tax
Gambling Tax
 Objects of gambling tax

 1) gambling tables and gambling machines used for organising
    games of chance and on gambling machines used for
    organising games of skill;
 2) in the event of organising a lottery, the total amount received
    from the sale of lottery tickets;
 3) in the event of organising a commercial lottery, the winning
    pot whose value exceeds 10 000 euros;
 4) in the event of organising a toto (betting+totalisator), the
    total amount net revenue of bets;
 5) in the event of organising an online game of chance or an
    online game of skill, the net revenue of bets;
 6) in the event of organising a tournament of a game of chance,
    the total amount of participation fees.

 Gambling tax is paid by gambling operators.
Gambling Tax
Tax rates:

1) for the gambling table – 1 278.23 euro per table in month;
2) for the gambling machine – 447.38 euro per in month euro
    per gambling machine;
3) 31.95 euro per gambling machine of game of skill;
4) 18 % from the sale of lottery tickets;
5) 18 % from the winning fund of the commercial lottery;
6) 5 % for the toto, amount received from net revenue;
7) 5 % for the online game, amount received from net
    revenue;
8) 5 % for the tournament of a game of chance (amount
    received from participation fees).
Plans for the future
Future Plans for Tax Policy

• Lower labour-related taxes and increased
  consumption-related and other indirect taxes
   – increase of excise duties
   – increase of environmental taxes
   – decrease of income tax
• Maintaining the current simple tax system
  and broad tax base.
• Improving tax administration
Plans for the future



The main goal for the future- shifting tax burden
from income and employment to consumption
and environmental taxes
Background information
Average Economic Growth in 2001–2011
Estonian real convergence with the EU
Labour market goals in Lisbon Strategy
Growth expectations

                      GDP growth,    Consumer price   Current account,
                           %            index, %         % of GDP
                      2012   2013     2012     2013    2012      2013
IMF                    2.0     3.6      3.9     2.6      2.4      2.3

Bank of Estonia        1.9     3.6     2.8*    2.9*      2.0      0.9

Ministry of Finance
(April 2012)
                        1.7    3.0     3.3      3.0      1.0      0.0

*HICP for BoE
General Government budgetary balance
             2004-2016




                 Source: Statistical Office of Estonia, Ministry of Finance
General Government tax burden
    1995-2016 (% of GDP)
General Government debt in 2010 (% of GDP)
Tax rate on low wage earners: Tax wedge
              on labour cost

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Estonian Taxes and Tax Structure 2012

  • 1. ESTONIAN TAXES AND TAX STRUCTURE Tax Policy Department Revised in 2012
  • 2. Population (01.01.2012) 1,339,662 Total area 45,227 km2 Average salary (2010) 792 EUR (2011 IV quarter) 865 EUR Currency EUR GDP (2011) 15,973 mill EUR Economic growth (forecast for 2012) 1.7% (forecast for 2013) 3.0% GDP per capita (2011) 11,918 EUR Inflation (forecast for 2012) 3.3%
  • 3. Outline of the presentation • The main principles of the Estonian tax system, the current tax structure • Taxation Act • Direct Taxes – Reasons for introduction of the flat rate in Estonia – The outcome of the reform – Personal Income Tax – Corporate Income Tax – Social Tax • Indirect taxes – VAT – Excise duties – Gambling tax • Plans for the future
  • 4. Estonian Tax System The main principles of Estonian tax policy: • simple tax system • broad tax base, low rates Estonia is a European pioneer in income taxation: • Flat income tax rate since 1994 (followed by Lithuania, Latvia, Russia, Ukraine, Serbia, Slovakia, Georgia, Romania, ..) • Unique corporate tax system since 2000
  • 6. Estonian Tax System • To achieve sustainable, socially and regionally balanced economic growth Estonian tax system consists of state taxes provided and imposed by tax acts and local taxes imposed by a rural municipality or city council in its administrative territory pursuant to law
  • 7. State taxes 1) excise duties; 2) income taxes; 3) gambling tax; 4) value added tax; 5) land tax; 6) social tax; 7) customs duty; 8) heavy goods vehicle tax.
  • 8. Local taxes 1) advertisement tax; 2) road and street closure tax; 3) motor vehicle tax; 4) animal tax; 5) entertainment tax; 6) parking charge.
  • 9. Taxation Act • Taxation act specifies – Estonian tax system – main definitions used in all tax acts – requirements for tax acts – rights, duties and liability of taxpayers, withholding agents, guarantors and tax authorities – regulations of the tax procedure and procedure for resolution of tax disputes – penalty interest rate 0,06% per day
  • 10. Taxation Act “Tax” is • a single or periodical financial obligation • imposed by an Act or by a local government council regulation according to Local Taxes Act • for the performance of the public law functions or to obtain revenue to perform these functions • subject to performance pursuant to the procedure, in the amount and on the due dates prescribed by an Act • collected without direct compensation therefore.
  • 11. Taxation Act Requirements for Act concerning tax 1) name of the tax; 2) object of taxation; 3) tax rate; 4) taxpayer; 5) recipient of or place of receipt of the tax; 6) due date or term for payment of the tax; 7) procedure for payment of the tax; 8) procedure for implementation of the Act concerning a tax; 9) possible tax incentives.
  • 12. Tax authority • The tax authority for state taxes is the Tax and Customs Board with its regional offices. The tax authority operates within the area of government of the Ministry of Finance. • Tax authority verifies the correctness of tax payments, assesses amounts of tax and interest due in the cases provided by law, collects tax arrears and implements sanctions against persons who violate tax Acts.
  • 13. Main tax rates • Corporate income tax – 21% on distributed profit • Personal income tax – 21% • Social tax – 33% (payable by employer) • Unemployment insurance payment – 2,8 % payable by employee and 1,4% payable by employer • Contribution to the mandatory funded pension system - 2% (payable by employee) • Value added tax - 20% (standard rate), 9% (reduced rate)
  • 15. Structure of tax burden (% of GDP) Source: Statistical Office of Estonia, Ministry of Finance
  • 16. Structure of general government tax revenue Source: Statistical Office of Estonia, Ministry of Finance
  • 17. Tax burden ( % of GDP) Source: Statistical Office of Estonia, Ministry of Finance
  • 18. State Budget Tax Revenue 2011 Total tax revenue 4,342.1 million EUR Total revenue 5,872.2 million EUR Source: Ministry of Finance
  • 19. Tax Revenue 2011, million € (collected) State taxes 4 342,1 Direct taxes 3 093,8 Personal income tax* 845,9 Corporate income tax 201,1 Social tax 1 801,4 Unemployment insurance 194,0 Land tax 51,5 Indirect taxes 2 112,3 VAT 1 343,3 Excise duties 717,0 Heavy vehicle tax 3,7 Customs tax 29,1 Gambling tax 19,3 Local taxes 25,5 * - The amount received by the state + local governments Source: Ministry of Finance
  • 21. Direct taxes • Personal income tax • Corporate income tax • Social tax • Land tax
  • 22. Reasons for introducing flat rate in Estonia
  • 23. Reasons for introducing flat rate in Estonia • High inflation rate - in case of flat rate there is no need of frequent adjustment of tax brackets • Flat rate system is easier to administer (for both taxpayers and tax administrators) • More transparency The new law entered into force on January 1st 1994.
  • 25. Personal income tax revenue 1994-2016 million € Source: Statistical Office of Estonia, Ministry of Finance
  • 26. Corporate income tax revenue million € * - includes revenue under the prior Income Tax Act (taxable period 1999)
  • 28. Personal income tax • Residents pay tax on their total worldwide income. • Non-residents pay tax only on their income received from Estonian sources. • Individuals are Estonian residents if they: - have a permanent home in Estonia, or - stay in Estonia 183 days or more during any 12-month period.
  • 29. Income Tax Act Period of taxation: a calendar year Tax rate: 21% (separate tax rate 10% for certain pensions and payments to non-residents) Decrease of the income tax rate (both for individuals and legal persons): Until the year 2004 – 26% Income of the year 2005 – 24% Income of the year 2006 – 23% Income of the year 2007 – 22% Since 2008 – 21%
  • 30. Income Tax Act Non-taxable minimum (annual basic exemption): 1728 EUR Additional exemption for state pensions: 2304 EUR for calendar year Increase of the non-taxable minimum (per year): Income of the year 2003 – 12 000 EEK (767 EUR) Income of the year 2004 – 16 800 EEK (1074 EUR) Income of the year 2005 – 20 400 EEK (1304 EUR) Income of the years 2006- 2007 – 24 000 EEK (1534 EUR) Income of the years 2008- 2010 – 27 000 EEK (1726 EUR) Since 2011 - 1728 EUR
  • 32. Personal income tax For non-residents there is a limited list of taxable income in the Income Tax Act: • income from work under a labour contract or contractor's agreement in Estonia; • income from a business carried on in Estonia; • interest income received from Estonia (only if it is substantially higher than that on similar debt claims); • royalties; • income from the lease of assets located in Estonia; • gains from disposal of assets located in Estonia; • directors' fees paid by Estonian enterprises; • income of a sportsman or an artist from his activities in Estonia • pensions and scholarships.
  • 33. Personal income tax For non-resident natural persons • Period of taxation is a calendar year • Tax rates: 21% and 10% • Estonia has 49 treaties for the avoidance of double taxation (income tax and capital taxes) in force
  • 34. Personal income tax Tax allocation of personal income tax paid by residents • The amount received by local governments is 11.4 % of taxable income (deductions are not taken into account), the excess amount is received by the state • Income tax paid on pensions and capital gain is received by the state Non-residents: • income tax is received by the state
  • 35. Personal income tax Avoidance of double taxation Natural persons • Exemption method for foreign dividends and certain salary income • Credit method for all other types of foreign income
  • 37. Corporate income tax • Corporate tax reform in year 2000 • The ultimate goal of the reform was promotion of business and acceleration of economic growth by making additional funds available for investment
  • 38. Corporate income tax Additional funds available for investment Stricter Transparency regulation and exchange of transfer of information pricing Acceleration of economic growth Elimination Introduction of technical of the CFC shortcomings rules
  • 39. Corporate income tax The moment of taxation of corporate income is postponed until the distribution of the profits The system applies to: • Estonian resident companies - legal persons that are established pursuant to Estonian law • permanent establishments (PE) of non-resident companies - PE is an entity through which the business of a non-resident is carried out in Estonia
  • 40. Corporate income tax The taxation of profit until 1999 Tax rate 26 % (on gross Income tax profit) 26 EUR Profit earned Dividend 100 EUR payment 74 EUR Time
  • 41. Corporate income tax Corporate income tax The timing of tax payment under the new system (since 2000)* The tax rate has been decreased since 2005 Income tax No tax 26 EUR Profit Tax rate 26/74 (on net amount, earned Dividend equals to 26% of gross profit) 100 EUR payment 74 EUR Time
  • 42. Corporate income tax • Tax rate in 2012: 21% (21/79 of the net amount) • Period of taxation: a calendar month
  • 43. Corporate income tax Tax base • corporate profits distributed in the tax period; dividends and other profit distributions, incl. liquidation proceeds and payments made on reduction of company’s equity or redemption or return of shares • taxable gifts, donations and representation expenses; • expenses and payments unrelated to business. Fringe benefits are taxable at the level of employer. Losses – taken into account (the Estonian Commercial Code does not allow to distribute profits if the company has losses from previous years)
  • 44. Corporate income tax Profit earned Gifts in 2009 100 EUR CIT (21/79) 27 200 EUR + Expenses unrelated to CIT (21/79) 80 Profit earned 1400 EUR potentially taxable income business on 2010 Total CIT 300 EUR liability 294 Tax liability deferred 1000 EUR CIT (21/79) 53 Donations + qualified 200 EUR dividend Dividend / Exemption received liquidation method Taxable Credit 100 EUR 640 EUR amount method + foreign 640 – 100 = 540 144 – 10 = 134 interest CIT (21/79) 144 received 100 EUR (source state WHT 10) Time
  • 45. Corporate income tax There are 3 main methods introduced in the Estonian Income Tax Act, the goal of which is to minimize the possibilities for tax fraud and evasion – CFC (Controlled Foreign Corporation) rules: residents have to declare and pay tax on the income of off-shore companies under their control – Stricter regulations for minimising the use of transfer-pricing schemes – Withholding tax of 21% on all payments to so-called off-shore companies for services
  • 46. Corporate income tax Avoidance of double taxation Companies and non-resident’s PEs • Exemption method for qualified (threshold 10%) profit distributions the income tax will not be charged on dividends or on payments upon reduction of share capital or contributions, redemption of shares or liquidation of a legal person on certain conditions. • Credit method for all other types of foreign income
  • 47. Structure of declared corporate income tax 2003-2016 million € Source: Statistical Office of Estonia, Ministry of Finance
  • 49. Social tax Tax Base • Employers' payments to natural persons (wage income) – tax payable by employers • in cash • in kind (fringe benefits) • Business income of sole proprietors – tax payable by self employed persons
  • 50. Social tax Period of taxation • Calendar month for wage income • Calendar year for business income of sole proprietors
  • 51. Social tax • Tax rate is 33 % of the taxable amount • Social tax payable is personificated and will be taken into account in making pension payments.
  • 52. Social tax • Tax allocation IF the person has joined the II pension pillar (compulsory for the persons who have born in 1983 or later; voluntary for older people) Social tax, rate 33% Contribution to the (payable by employer or self II pillar (made by employed person) employee) 13% 16% 4% 2% State health State pension Personal pension insurance insurance system account of the person (II system (I pillar) pillar) 2% + 4%= 6%
  • 53. Social tax revenue 1994-2016 million € Source: Ministry of Finance
  • 54. Structure of declared social tax 2003-2016 million € Source: Statistical Office of Estonia, Ministry of Finance
  • 56. Indirect taxes • Value added tax • Alcohol excise duty • Tobacco excise duty • Energy products excise duty • Packaging excise duty (budget revenues insignificant) • Heavy goods vehicle tax • Gambling Tax
  • 58. VAT Taxable person • Person whose taxable supply (excluding import) exceeds 16 000 EUR in a calendar year • Voluntary compliance possible for anyone, who carries out economic activity in Estonia
  • 59. VAT Tax base VAT is charged on: • transactions of goods and services within Estonia • intra-Community acquisitions of goods and services • importation of goods and services • provision of services which are taxable in Estonia, supplied by the foreign taxable person
  • 60. VAT Tax rates • Standard rate is 20%. • Reduced rate is 9% (books, newspapers, medicines, accommodation). • Zero rated: export; intra-Community supply; vessels and aircrafts used on international routes, including equipment and fuel; goods and services for consumption supplied on board of vessels and aircrafts.
  • 61. VAT Exempted goods and services are: • postal services • health services • social services • insurance services • services for the protection of children • transportation of sick, injured or disabled persons • supply of immovables • the leasing and letting of immovables, etc.
  • 62. VAT revenue 1994-2016 million € Source: Statistical Office of Estonia, Ministry of Finance
  • 64. Duty rates • Alcohol and tobacco products – all rates meet EU minimum levels • Energy products – all rates meet the EU minimum levels except for oil shale for which there is a transitional period up to 2013
  • 65. Excise duty rates on alcohol 01.02.2012 Excise duty rates in EU minimum Unit euros excise duty rates Wine and fermented (up to 6 %): 33,30 Hectolitre 0 beverage (> 6 %): 76,80 5,70 Beer 1 % alcohol in (yearly production up 1,87 hectolitre to 3000 hl): 2,85 Intermedi- ate product Hectolitre 164,00 45 Hectolitre of Other pure alcohol 1490 550 alcohol
  • 66. Excise duty rates on tobacco products 01.01.2012 Product Excise duty rates EU minimum in euros excise duty rates CIGARETTES: Specific rate 42,18 64 EUR per 1000 cigarettes, (1000 cigarettes) but not less than Ad valorem rate 57 % from weighted average ( % of the retail selling 33 % price of cigarettes price) CIGARS 12 EUR or 5% from the retail (1000 cigars) 191,73 selling price CIGARILLOS 12 EUR or 5% from the retail (1000 cigarillos) 191,73 selling price SMOKING TOBACCO 55,79 40 EUR or 40% from the retail (1 kg ) selling price
  • 67. ENERGY PRODUCTS: national excise duty rates on MOTOR FUELS and the EU minimum excise levels ENERGY Excise rates in Estonia The EU minimum levels of PRODUCT 01.01.2012 taxation Unleaded 422,77 EUR/ 359 EUR/ petrol 1000 l 1000 l Leaded petrol 422,77 EUR/   1000 l Gas oil 392,92 EUR/ 330 EUR 1000 l 1000 l Gas oil for 110,95 EUR/ 21 EUR/ specific 1000 l 1000 l purposes LPG 125,26 EUR/ 125 EUR/ 1000 kg 1000 kg Petroleum 330,1 EUR/ 330 EUR 1000 l 1000 l
  • 68. National excise duty rates applicable to heating fuels and electricity and the EU minimum excise levels Energy Excise rates in The EU minimum levels of taxation product Estonia 01.01.2012 business non-business Light fuel 110,95 EUR/ 21 EUR/ 21 EUR/ oil 1000 l 1000 l 1000 l Heavy fuel 15,01 EUR/ 15 EUR/ 15 EUR/ oil 1000 kg 1000 kg 1000 kg Petroleum 330,1 EUR/ 1000 l - - Natural 23,45 EUR/ 0,15 EUR/ GJ 0,3 EUR/ GJ gas 1000 m3 Coal and 0,3 EUR/ GJ 0,15 EUR/ GJ 0,3 EUR/ GJ coke Electricity 4,47 EUR/ 0,5 EUR/ 1 EUR/ MWh MWh MWh
  • 69. Excise duty revenue 1994-2016 million € Source: Statistical Office of Estonia, Ministry of Finance
  • 70. Packaging excise duty Object of taxation: Excise duty on packaging shall be imposed on packaging of goods placed on the market in Estonia or acquired in and imported from another Member State of the European Union. Exemption from excise duty incidentally are: 1) packaging concerning which a deposit has been established under the Packaging Act, except metal packaging of beverages, and from which at least 85 percent of each class of packaging material is recovered as of 1 January 2012;
  • 71. Packaging excise duty 2) metal packaging of beverages of which of which at least 50 percent is recovered as of 1 January 2010; 3) as of 1 January 2009, other packaging recovered to the extent provided for in § 36 of the Packaging Act.
  • 73. Gambling Tax Objects of gambling tax 1) gambling tables and gambling machines used for organising games of chance and on gambling machines used for organising games of skill; 2) in the event of organising a lottery, the total amount received from the sale of lottery tickets; 3) in the event of organising a commercial lottery, the winning pot whose value exceeds 10 000 euros; 4) in the event of organising a toto (betting+totalisator), the total amount net revenue of bets; 5) in the event of organising an online game of chance or an online game of skill, the net revenue of bets; 6) in the event of organising a tournament of a game of chance, the total amount of participation fees. Gambling tax is paid by gambling operators.
  • 74. Gambling Tax Tax rates: 1) for the gambling table – 1 278.23 euro per table in month; 2) for the gambling machine – 447.38 euro per in month euro per gambling machine; 3) 31.95 euro per gambling machine of game of skill; 4) 18 % from the sale of lottery tickets; 5) 18 % from the winning fund of the commercial lottery; 6) 5 % for the toto, amount received from net revenue; 7) 5 % for the online game, amount received from net revenue; 8) 5 % for the tournament of a game of chance (amount received from participation fees).
  • 75. Plans for the future
  • 76. Future Plans for Tax Policy • Lower labour-related taxes and increased consumption-related and other indirect taxes – increase of excise duties – increase of environmental taxes – decrease of income tax • Maintaining the current simple tax system and broad tax base. • Improving tax administration
  • 77. Plans for the future The main goal for the future- shifting tax burden from income and employment to consumption and environmental taxes
  • 79. Average Economic Growth in 2001–2011
  • 81. Labour market goals in Lisbon Strategy
  • 82. Growth expectations GDP growth, Consumer price Current account, % index, % % of GDP 2012 2013 2012 2013 2012 2013 IMF 2.0 3.6 3.9 2.6 2.4 2.3 Bank of Estonia 1.9 3.6 2.8* 2.9* 2.0 0.9 Ministry of Finance (April 2012) 1.7 3.0 3.3 3.0 1.0 0.0 *HICP for BoE
  • 83. General Government budgetary balance 2004-2016 Source: Statistical Office of Estonia, Ministry of Finance
  • 84. General Government tax burden 1995-2016 (% of GDP)
  • 85. General Government debt in 2010 (% of GDP)
  • 86. Tax rate on low wage earners: Tax wedge on labour cost

Editor's Notes

  1. The main objective of the medium-term fiscal framework is to ensure conditions for economic stability and sustainable development through budgetary system. Due to the prescriptions of the currency board arrangement, the fiscal policy is the main instrument for the government to influence economy. The government has set balanced budget as its objective, thus trying to make opportunities for further stabile development. Objectives have been set up to ensure long-term economic stability, the stability of the financial system and compliance with international requirements. Balanced fiscal policy determines maintaining conservative lending policies.