As of 15 August 2023, Estonia has signed and ratified 64 tax treaties, out of which 62 tax treaties have entered into force. Since the latest Action 14 peer review report, the tax treaty with Guernsey has entered into force on 6 August 2020 and the tax treaty with Mauritius on 12 October 2021. Both treaties are in line with the Action 14 minimum standard. The MLI entered into force for Estonia on 1 May 2021. Estonia submitted its first notification under Article 35 (7) (b) of the MLI on 25 November 2021 covering seven tax treaties. Next notification was submitted on 1 June 2022, which also covered seven tax treaties. As a result of these notifications the first sentence of paragraph 1of Article 25 was updated by the MLI in accordance with OECD Model Tax Convention (2017) in eight tax treaties and in case of two tax treaties the second sentence of paragraph 3 of Article 25 was added.
Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023
OECD/G20 Base Erosion and Profit Shifting Project
Estonia
Recent developments relating to MAP in Estonia prior to 15 August 2023
Developments relating to MAP in the tax treaty network
Other developments relating to MAP
No developments were reported
Latest Action 14 Peer Review report
25 May 2021, https://doi.org/10.1787/332796fc-en
Tax treaty network of Estonia
64 treaties, applicable to 64 jurisdictions (covering all treaties signed, although not necessarily in force)
status of MLI: in force.
Table 1. State of play of Estonia's tax treaty network
Source: OECD
Estonia's MAP programme
Organisation of competent authority function
six persons:
one head(s) of unit
five persons working on MAP cases (all of which work on other tasks as well).
contact persons for MAP requests:
Mrs Merje Roomet, Chief expert of tax department, the Estonian Tax and Customs Board Lõõtsa 8 a, Tallinn, 15176 phone + 372 676 2124 map@emta.ee, www.emta.ee.
Figure 1. Competent Authority Organisational Structure
Source: OECD
Table 2. Guidance on the MAP process
Overview of Estonia's MAP Statistics for 2022
Please refer to https://www.oecd.org/tax/dispute/map-statistics-estonia.pdf for details with respect to Estonia's MAP Statistics.
Figure 2. Cases closed in 2022
Source: OECD
Figure 3. Evolution of Estonia's MAP caseload (2016-22)
Source: OECD
Table 3. Overview of Estonia’s MAP caseload for 2022
Source: OECD
Table 4. Estonia’s average time to resolve MAP cases in 2022
Source: OECD