Tax in Estonia

Cobalt

The tax team at Cobalt is known for representing international clients in tax disputes, as well as providing tax advisory services. It also has niche expertise in corporate tax incentives and benefits. Practice head Egon Talur focuses on repressing clients in tax litigation and audit proceedings. Senior associate Tõnu Kolts is particularly strong in tax structuring and advising on Estonian employee share option practices, while senior associate Karli Kütt represents clients in indirect tax and tax proceedings, covering VAT, excise duties, and customs duties.

Practice head(s):

Egon Talur

Other key lawyers:

Karin Kütt; Tõnu Kolts

Testimonials

‘Attentive to detail, proactive, responsible, and client-oriented.’

‘Egon Talur is a very professional and client oriented partner. Karli Kutt is responsible and proactive.’

Key clients

Change Ventures

Mindvalley, Inc.

Green Marine, a joint venture of Port of Tallinn Ltd. and NT Marine Ltd.

Modular Technologies

3 Commas Technologies

Manoir Energy

Alexela Group

Johnson & Johnson

Nordic Aviation Group

Omnicom Media Group Europe Limited

Diarana

Work highlights

  • Advised Green Marine AS on obtaining an operating license for an excise warehouse required for the production and processing of heavy fuel oil.
  • Advised Fortumo on all Estonian tax matters with respect to selling its business to global mobile payments platform Boku.
  • Advised Mindvalley, Inc., and its Estonian subsidiary Mindvalley OÜ, on various tax-related matters.

Ellex

Ellex is a key resource for international and Estonian clients seeking advice regarding indirect tax, real estate tax, structured finance, and tax audits, investigations, and disputes. Its clients are often active in regulated industries  as well as manufacturing, engineering, transport, and media, among others. Tax specialist and practice head Dmitri Rozenblat handles tax disputes and advises on international taxation matters. He is also well versed in M&A transactions and corporate restructuring.

Practice head(s):

Dmitri Rozenblat

Testimonials

‘We have had excellent collaboration with one key contact, with him drawing in the required expert colleague where needed.’

We specifically want to highlight the expertise of Dmitri Rozenblatt. He has coordinated working out new operating structure to optimize VAT treatment in our business. To achieve this, we worked closely with relevant authorities. In addition, we benefited from subsequently transferring the same solution into a neighbouring country.’

Key clients

Tere AS

East Capital

Estonian Chamber of Commerce and Industry

AS LHV Group

Coop Pank AS

AS Inbank

AS Operail

Amserv Grupi AS

ABC Grupi AS

Danske Bank A/S

BaltCap

Spacecom AS

Maag Group

OÜ Skeleton Technologies Group

Work highlights

  • Advised Graanul Invest AS and its shareholders on the tax structuring of the sale of the majority shareholding in Graanul Invest AS and other complex tax aspects related to the exit transaction.
  • Advised Checkout Payments Group Limited on the tax structuring and other complex tax aspects related to the purchase of Icefire Holding OÜ.
  • Advised Saint-Gobain Glass Estonia SE, part of the Saint-Gobain Group on the tax aspects of the Group’s employee incentive programme.

HansaLaw OÜ

The boutique tax team at HansaLaw OÜ is known for exclusively focusing on tax and customs, with particular emphasis on criminal matters, administrative proceedings, and civil cases. It has notable strength advising on tax-related transactional and compliance work. Practice co-heads Vahur Kivistik and Gerly Kask specialise in administrative and tax law, often dealing with tax and customs disputes.

Practice head(s):

Vahur Kivistik; Gerly Kask

Other key lawyers:

Jüri Leppik; Tõnu Tuulas; Heidi Rajamäe-Parik

Key clients

Adelan KVH OÜ

Floberg Capital OÜ

Kalf VK OÜ

Petroil PVTK OÜ

Panamir OÜ

Ants Mäelt

Work highlights

  • Represented Adelan KVH OÜ in a business transfer dispute valued at €1.29m.
  • Represented real estate company Porto Investments OÜ on a matter related to tax-free dividends paid to a shareholder.
  • Advised Eesti-Ukrania Ehitaja OÜ on a VAT exemption case.

LEADELL Pilv

LEADELL Pilv is a key resource for international clients seeking representation in pan-Baltic tax disputes. ‘Very experienced and professional' practice head Aivar Pilv often defends clients before the Estonian Tax and Customs Board regarding contentious tax matters.

Practice head(s):

Aivar Pilv

Testimonials

‘Hard working and result-oriented.’

‘Always available, very professional.’

‘They are very experienced in tax court cases and therefore have been helpful in solving some taxation questions we have had.’

‘Aivar Pilv is very experienced and professional.’

Key clients

AS Saarek

Kruuson Kaubandus OÜ

Surgitech AS

Work highlights

  • Counselled AS Saarek on day-to-day various legal questions (including tax law).
  • Advised Kruuson Kaubandus OÜ on day-to-day various legal questions (including tax law).
  • Counselled Surgitech AS on day-to-day various legal questions (including tax law).

Sorainen

Sorainen provides highly regarded expertise in tax due diligence, transfer pricing, and tax compliance, especially when linked to M&A transactions in Estonia. It also advises Estonian government bodies on key tax matters. Practice head Paul Künnap is noted for his tax-related work relating to corporate restructuring and other corporate matters. Counsel Kärt Anna Marie Kelder advises private individuals on the full range of tax issues in Estonia, as well as acting for key players in the energy and pharmaceutical sectors. Senior associate Tanel Molok focuses on VAT and corporate income tax matters. Tax specialist Kaido Künnapas was promoted to counsel in April 2021; he advises start-ups and venture capital groups on tax matters such as share option arrangements and VAT.

Practice head(s):

Paul Künnap

Other key lawyers:

Kärt Anna Marie Kelder; Tanel Molok; Kaido Künnapas

Testimonials

‘Very approachable, always get the scope of the problem quickly, they stick to their agenda and scope, pro-business minded, solve problems practically rather than theoretically, always find time to chat, friendly and down-to-earth people.’

Sorainen have been super responsive, open and have shared experience and best / latest practice and innovation via webinars and group calls, keeping me informed and educated about issues, many of which are new for me.’

The team is exceptionally well set up, both in terms of factual legal knowledge as well as their communication skills. We were very happy that we had them at our side in a difficult legal question that span over multiple countries and languages.’

Kärt Kelder is a person who has a deep understanding of the relevant legal framework. She also can foresee the potential risks/issues between different jurisdictions. She can understand the needs from the client’s perspective. Her mindset is towards finding out solutions.’

Kaido Künnapas is very approachable, always get the scope of the problem quickly, pro-business minded, solves problem practically rather than theoretically.’

Key clients

Green Tiger

Paikre

Splunk

Vista Equity Partners

Bolt Technology

Komatsu Financial Europe

Mehiläinen

Work highlights

  • Advised Green Tiger on tax regulations.
  • Advised Vista Equity Partners on its majority investment in Pipedrive and addressed tax topics related to the acquisition.
  • Advised Bolt Technology on different cross-border tax issues.

TGS Baltic

TGS Baltic is particularly strong in tax litigation for international corporate clients. It also provides day-to-day corporate tax advice on areas such as excise duty tax, income tax, and VAT. Practice head Helmut Pikmets is a tax disputes specialist, frequently appearing before the Supreme Court of Estonia and the Office of the Chancellor of Justice regarding tax-related constitutional review proceedings. Senior associate Sergei Jegorov is noted for his work in corporate tax-related restructurings and risk assessments.

Practice head(s):

Helmut Pikmets

Other key lawyers:

Sergei Jegorov

Key clients

Luminor (formerly Nordea Bank Finland Plc Estonian branch)

Tallink Group

Swedbank

Imatra Elekter

Baltic Ground Services

HKScann

Metrosystem

Euroapteek

ESTIKO

Circle K

Sanofi

Møller Eiendom group

Proplastik

TBD-Biodiscovery

Invego

Endover

MAXIMA Estonia

EstHus

Starbunker

Baltcap

EstateGuru

Auto-Bon/Bassadone

Bondora group

Opera

Work highlights

  • Advised Opera group on signing the share purchase agreement for the acquisition of a banking-as-a-service provider PocoSys and its sister company, the EU-licenced Pocopay from Poco Holding.
  • Represented Mutiforce against the Tax and Customs Board in the Tallinn Administrative Court in connection with the request of the Tax Board of the Russian Federation (within the framework of the OECD agreement) to request information and documents from the client.
  • Advised CityJet DAC on the taxation of labour taxes relating to international flights as well as represented it in communication with the Estonian Tax Board regarding the international taxation of labour taxes.

WALLESS (former Derling Primus)

WALLESS is widely known for its strength in advising European corporations seeking tax support during relocation to Baltic countries. It also covers tax disputes and court proceedings, tax fraud and criminal cases, and tax structuring and compliance. Additionally, it has advised Scandinavian high-net-worth individuals transferring residence and holding property in the Baltics. Practice head Rolan Jankelevitsh focuses on tax, corporate and commercial law, as well as drafting tax legislation. Counsel Priit Raudsepp was previously at the Estonian tax authority and specialises in international tax planning for multinationals.

Practice head(s):

Rolan Jankelevitsh

Other key lawyers:

Priit Raudsepp

Key clients

HeidelbergCement

Gazpromneft Marine Bunker

Nortal group

Fort Aero

Eolane Group

Estonian Association of Media Enterprises

Work highlights

  • Advised Mandatum Life on the Estonian tax implications of the sale of the life insurance business to the Lithuanian acquirer Invalda group.
  • Advised the Estonian Association of Media Enterprises on possible introduction of the digital services tax in Estonia.
  • Acted as a defence counsel to a former owner and CEO of TERE AS in a high-profile criminal case involving the tax authority accusing the client of committing various tax crimes.

ATTELA Advokaadibüroo

The boutique specialist tax practice at ATTELA Advokaadibüroo has an established reputation advising clients on international and domestic tax law in Estonia. In recent years, it has also branched out into assisting with the tax-related aspects of cryptocurrency and blockchain for clients in the IT sector. Tax litigation expert Marek Herm is also an experienced advisor on bilateral tax treaties. Marko Saag focuses on tax-related issues concerning M&A and financial structuring, while Kaspar Lind specialises in tax evasion disputes and VAT.

Practice head(s):

Marek Herm; Marko Saag; Kaspar Lind

Other key lawyers:

Madis Uusorg

Testimonials

‘The people think out of the box and give you the advice you really need.’

‘Madis Uusorg has been a good partner for us for years. We have had different questions in the past and he has come up with adequate solutions every time.’

‘All the persons who work in Attela are great experts in tax law. They have wonderful co-operation with each other, because they communicate every day not only on the working matters, but also as individuals.’

‘The team has extensive knowledge on tax law.’

‘The individuals that I work with are devoted to the client and often work even out of ordinary working hours in order to find the best solution for the client. Especially I would like to point out Marek Herm.’

‘They are focused on taxation and business law and are able to solve problems in a complex way, which is important for the entrepreneur, because the advisor / lawyer sees the problems more broadly and finds solutions.’

‘Kaspar Lind has represented us in court proceedings and has also effectively applied his knowledge in shaping the structure of our companies. Madis Uusorg has designed tax-relevant processes and communicated effectively with the tax authority and brought clarity to issues that are important to us. It has been important for us to have direct contact and a quick response to our questions, which Attela has offered us.’

‘Kaspar Lind is the best in his field. He is really multiskilled, versatile, 360 degree thinking and finds solutions where others fail.’

Key clients

Amon

Orvium

Lightstreams

AS East-West Consulting

EESTI SPORDISELTS KALEV

ScanBalt Trucks

Alpter Grupp

Kroonikeskus

Work highlights

  • Represented EESTI SPORDISELTS KALEV in two separate court cases concerning the transfer of an enterprise and transferor’s obligations related to the enterprise as well as liability of the board member of the transferor company.
  • Advised Amon on receiving investments for its blockchain business.
  • Represented Maximus International against a credit institution in Tallinn Circuit Court regarding whether credit institutions are prevented from closing payment accounts of clients without a good reason and any contrary term in the service agreement is void.

Eversheds Sutherland Ots & Co

Eversheds Sutherland Ots & Co specialises in a number of tax-related areas, including international and domestic tax litigation, due diligence, planning, and representing clients before the Estonian Tax and Customs Board and Supreme Court of Estonia. It also covers tax in the IT sector, as well as specialist work in employment and the establishment of corporations in the Baltics and Nordics. Head of the tax team Toomas Pikamäe is experienced in a wide range of tax-related areas, including Estonian tax law and excise duties, VAT and transfer pricing.

Practice head(s):

Toomas Pikamäe

Key clients

Just Print OÜ

Confido Healthcare Group OÜ

E-Piim Tootmine AS

Toftan AS

Rovoler OÜ

Venten OÜ

Xolo OÜ

Oy Transmeri Group Ab

Samsung Electronics Baltics SIA

Baltem AS

Work highlights

  • Advised E-Piim Tootmine AS on international payroll tax issues concerning the employment of foreign specialists for the work in Estonia. The advice included social security insurance matters for the family members of the foreign specialists.
  • Advised Toftan AS on the taxation of the company’s Swedish investments under the Estonian-Swedish Double Tax Convention.
  • Assisted Xolo OÜ, along with Finnish tax advisors, in the matter of the company’s possible permanent establishment in Finland, and representation in communications with the Finnish Tax Authorities.

Magnusson

The tax advisory group at Magnusson is noted for its geographically expansive coverage in the Baltics and the Nordics as well as its expertise in tax risk management, market entry and tax planning, and cross-border tax restructuring. It covers day-to-day tax due diligence and auditing, as well as more controversial tax matters, including representation before the Estonian Supreme Court. Practice head Elvira Tulvik is an expert in cross-border tax and regulatory matters, especially concerning transactions and market entry into the Nordics and Baltics.

Practice head(s):

Elvira Tulvik

Key clients

World Bank

Bergé Auto

DEPO

Saint-Gobain Group

Flixbus

Work highlights

  • Advised World Bank on its €20m investment into Bolt by performing a tax due diligence of the Estonian targets, which are part of Bolt group, as part of a multinational due diligence.
  • Advised on the tax issues regarding the reorganisation of the Saint-Gobain group with the aim of optimising ownership and management structure, and financing.
  • Assisted DEPO DIY SIA in its company establishment in Estonia and provided an extensive tax and legal analysis for different areas of activity in Estonia for its prospective expansion.

RASK Attorneys-at-Law

RASK provides ‘valuable insight‘ to international clients on matters including Estonian market entry, as well as other cross-border tax matters such as corporate relocation. Villy Lopman is a notable tax dispute expert, having advised clients ranging from start-ups to major Estonian state authorities and tax bodies on both tax-related criminal cases and complex commercial disputes. Annika Soom specialises in international tax restructurings and transfer pricing, and has been involved in high-value tax disputes.

Practice head(s):

Villy Lopman; Annika Soom

Testimonials

‘My experience with RASK has been fully pleasant. From the first moment, everything has been great. Communication has been smooth with both attorneys and administration. What impressed me was the fast pace, competent advice and friendly relations. So far, my expectations have not only been met but also exceeded.’

‘My main contact is Villy Lopman. He is truly an expert in his field and therefore I can completely rely on getting useful advice from him. Also, Annika Soom has proved to be an extremely helpful source for any tax issues. She is very competent, quick to reply, as well as offers a clear timeline and makes sure the client is satisfied.’

‘I find RASK attorneys always easily accessible, whether it is about an urgent matter that needs to be discussed on the phone, setting up a meeting with the attorneys, billing or other issues. They work well as a team and provide good legal advice.’

‘The three people I am mostly in contact with are Villy Lopman and Annika Soom. Proven their value and professionalism in their fields of expertise. They are genuinely invested in their work, provide good legal counsel and also bring valuable insight on the bigger picture, best strategic moves and long-term outcomes.’

‘Excellent knowledge of tax regulations, ability to operate with complex structures (group companies across different jurisdictions).’

‘Annika Soom is very helpful, available, good understanding of underlying business needs. Great quality in delivery. Exceeded expectations.’

‘The team is full of very capable and engaging people, who take their work seriously. I cannot bring examples of innovations, but their commitment to quality and deadlines was exceptional.’

‘Our collaboration was quick and efficient, they were knowledgeable, but at the same time open to ideas from our side.’

Key clients

AS Maag Grupp

Kündig Bio Agrarprodukte GmbH

EstateGuru OÜ

Forever New Clothing UK Ltd

Kuressaare Hospital

Estonian Autosport Events MTÜ

Sihtasutus Bocuse d’Or Tallinn 2020

KPMG Law in Estonia

The tax team at KPMG Law in Estonia is experienced in advising and representing both local and international corporations on all relevant tax matters, including tax compliance, transfer pricing, indirect tax and litigation. It is particularly noted for its strengths regarding tax-related immigration procedures and cryptocurrency. Practice head Joel Zernask is known for reaching tax agreements and clearance for corporate structures with Estonian authorities.

Practice head(s):

Joel Zernask

Testimonials

‘Customer service was top quality. The team was friendly and dedicated, professional and customer-driven. It was good to see that the team focused on details, studied the market practice all over Europe and provided thorough advice.’

‘Very professional individuals and good understanding of my expectations.’

‘KPMG is on a great level as always.’

‘Joel Zernask and Kaia Kuusler are exceptional advisers.’

‘The team is customer oriented, easy to approach, innovative minded, high level of professionalism.’

Key clients

Infortar

Eesti AGA

Capital Mill

Partners Group

Ekspress Grupp

Maag Grupp

Lidl Stiftung & Co. KG

BaltCap

Philip Morris

Stockmann

Work highlights

  • Advised Lidl group on its establishment in Estonia, posting of hundreds of employees across Europe for internship purposes, and handled tax affairs both internationally and domestically.
  • Advised Evecon on group structuring and communication with state authorities.
  • Advising Forecast Foundation on the restructuring of transactions for tax purposes, statutory reporting and management responsibilities.