List of territories which are not regarded as low tax rate territories

The list of territories which are not regarded as low tax rate territories, is established with a regulation of the Minister of Finance.

In alphabetical order

  1. Canada
  2. Czech Republic
  3. Federal Republic of Germany
  4. French Republic
  5. Georgia
  6. Grand Duchy of Luxembourg
  7. Hellenic Republic (Greece)
  8. Hungary
  9. India
  10. Ireland
  11. Isle of Man
  12. Italian Republic
  13. Japan
  14. Jersey
  15. Kingdom of Bahrain
  16. Kingdom of Belgium
  17. Kingdom of Denmark
  18. Kingdom of Norway
  19. Kingdom of Spain
  20. Kingdom of Sweden
  21. Kingdom of Thailand
  22. Kingdom of the Netherlands, except Aruba, Sint Maarten and Curaçao
  23. People’s Republic of China, except Hong Kong, Aomen (Macao)
  24. Portuguese Republic
  25. Republic of Albania
  26. Republic of Armenia
  27. Republic of Austria
  28. Republic of Azerbaijan
  29. Republic of Belarus
  30. Republic of Bulgaria
  31. Republic of Croatia
  32. Republic of Cyprus
  33. Republic of Finland
  34. Republic of Iceland
  35. Republic of Kazakhstan
  36. Republic of Korea
  37. Republic of Latvia
  38. Republic of Lithuania
  39. Republic of Malta
  40. Republic of Moldova
  41. Republic of North Macedonia
  42. Republic of Poland
  43. Republic of Serbia
  44. Republic of Singapore
  45. Republic of Slovenia
  46. Republic of Turkey
  47. Republic of Uzbekistan
  48. Romania
  49. Slovak Republic
  50. Socialist Republic of Vietnam
  51. State of Israel
  52. Swiss Confederation
  53. Turkmenistan
  54. Ukraine
  55. United Arab Emirates
  56. United Kingdom of Great Britain and Ireland, except Anguilla, Bermuda, British Virgin Islands, Cayman Islands, Gibraltar, Guernsey, Montserrat, Turks and Caicos Islands
  57. United Mexican States
  58. United States of America, except United States Virgin Islands and Marshall Islands

About low tax rate territories

Estonia does not have an official list of countries that are regarded as low tax rate territories.

A legal person, which generates more than 50% of its annual revenue from actual economic activities, or whose country or territory of location provides tax authorities with information concerning the income of a person under the control of residents of Estonia, is not considered to be located in a low tax rate territory.

Legal persons whose transactions are not ostensible are deemed to be engaged in genuine economic activity. The characteristics of an ostensible transaction are: an incorrect legal form and intent to evade taxes, the lack of economic purpose, and the artificial nature of the transactions.

If the aforementioned conditions are not fulfilled, the taxpayer has to be able to prove that the trading partner is not located in a low tax rate territory, for example, with a certificate of income tax liability of the legal person in that foreign country certified by a tax authority of the country.

The taxpayer is obligated to prove that the transactions have been carried out in good faith and for business purposes.