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Pillar Two – Domestic Implementation

Estonia and the Pillar Two GloBE rules

Pillar Two GloBE Rules and Estonia’s Distribution Tax

A key issue with a distribution tax regime such as Estonia’s is that a company may not distribute profits for a number of years. They would have GloBE income but no or limited tax suffered on that income which would lead to a sizeable Pillar Two top-up tax liability. As such a distribution tax regime election is available.

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