Estonia

Transfer Pricing in Estonia

Estonian transfer pricing (siirdehinnad) for tax year 2026: Estonian companies, permanent establishments of foreign companies and sole proprietors (FIE) dealing with associated persons. Covers who is associated under Income Tax Act § 8, the arm's length rule in § 50(4) (companies), § 14(7) (FIE) and § 53(4⁶) (permanent establishments), how an adjustment is taxed at 22/78 in the monthly TSD like a profit distribution, Minister of Finance Regulation No. 53 (methods, 5% low value-adding services mark-up, master file and local file), who must keep full files (250 staff, EUR 50m turnover or EUR 43m balance sheet with associated persons; banks, insurers, listed companies), the 60-day production deadline, fines, interest at 0.06% a day, country-by-country reporting at EUR 750m, MAP and why there is no domestic APA or binding ruling.