Transfer pricing in Estonia

Transfer pricing in Estonia at a glance

Regulation Type OECD
Are there specific transfer pricing regulations? Yes
Submission deadline N/A
Submission deadline upon request No shorter than 60 days
Annual update required No
Official language requirements Estonian (English generally accepted)
Potential impact of penalties N/A

 

Estonian tax law

Rules for transfer pricing in Estonia are based upon:

  • Estonian Income Tax Act articles 8, 14, 50, 53
  • Transfer pricing regulation of 10 November 2006 (no. 53)

OECD

Rules for transfer pricing in Estonia are based on the OECD Transfer Pricing Guidelines. However, national legislation prevails over the OECD Transfer Pricing Guidelines.

Methods

Accepted methods

Accepted methods are:

  • the comparable uncontrolled price method;
  • the resale price method;
  • the cost plus method;
  • the profit split method;
  • the transactional net margin method, and
  • other methods that provide an arm’s length result.

Priority of methods

Rules for transfer pricing in Estonia do not provide for any specific transfer pricing method.

Documentation requirements

Information that should be included in the documentation:

  • Company analysis;
  • Industry analysis;
  • Functional analysis, and
  • Economic analysis. 

Language

Rules for transfer pricing in Estonia prescribe that documentations should be submitted in Estonian. However, generally documentation in English is also accepted.

Requirements to prepare documentation annually 

Rules for transfer pricing in Estonia require that detailed transfer pricing documentation should be provided for every financial year.

Submission deadline upon request by tax authorities

Upon request, a taxpayer is given a period of time to submit the documentation. This period may not be shorter than sixty days.

Advanced Pricing Agreements

General

Rules for transfer pricing in Estonia do not provide for Advanced Pricing Agreement regulations.

Terms

Not applicable.

Penalties

Rules for transfer pricing in Estonia do not provide specific transfer pricing penalties.

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