Tax in Estonia

Cobalt

Cobalt focuses on cross-border tax structuring for local clients and inbound tax structuring for multinational clients. The team also deals with tax structuring arising from M&A deals, indirect taxation and incentives and benefits. Practice head Egon Talur provides day-to-day tax advice and has extensive experience of audits and tax litigation. Associates Karli Kütt and Tõnu Kolts are also noted.

Ellex

Tax specialist Dmitri Rozenblat, who heads the practice at Ellex, is invaluable in his advice on issues arising from corporate restructuring and M&A. The team also handles a good deal of standalone tax work, including international taxation, investigations and disputes, and indirect tax. Other areas of strength include finance-related tax matters related to asset finance and investment funds.

Practice head(s):

Dmitri Rozenblat

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

  • Advising Bolt, an international information society services provider, on designing a complex tax and invoicing structure for the client’s food delivery business line.
  • Advising Danske Bank on complex tax matters related to its exit from the Estonian market and transferring its financial portfolio from Danske Bank A/S Estonian branch to Danske Bank A/S Lithuanian branch.
  • Advising Merck Sharp & Dohme on the tax optimisation of its distribution network in the Baltic states, in particular regarding VAT deductible on rebates that are granted to local health insurance organisations.

HansaLaw OÜ

Boutique firm HansaLaw OÜ specialises exclusively in tax and customs advice, handling a broad variety of transactional, compliance and disputes work. Founder Vahur Kivistik leads the team along with Janar Urres, who focuses on administrative and criminal cases, and Gerly Kask.

Practice head(s):

Vahur Kivistik; Gerly Kask; Jüri Leppik

Testimonials

‘Gerly Kask was leading the our case extremely well and professionally. She was informing and planning strategy smartly and we won the case, which was extremely complicated.’

LEADELL Pilv

LEADELL Pilv is best known for its contentious tax expertise; the group defends both corporates and privates persons and is capable of handling large multi-jurisdictional disputes. The practice also provides day-to-day tax advice. Managing partner Aivar Pilv heads the team, and has a strong track record in substantial tax disputes.

Practice head(s):

Aivar Pilv

Testimonials

‘Very professional.’

‘Hardworking.’

Key clients

AS Saarek

Kruuson Kaubandus OÜ

Work highlights

  • Advising AS Saarek on a day-to day-basis on tax matters.
  • Advising Kruuson Kaubandus on a day-to day-basis on tax matters.

Sorainen

Sorainen’s tax and customs team has a strong reputation for compliance and advisory work, and handles transfer pricing and due diligence for corporate clients. The practice has advised the Estonian Ministry of Finance and the Estonian Financial Supervision authority. Group lead Paul Künnap regularly deals with tax issues arising from corporate restructuring. Of counsel Kärt Anna Maire Kelder is noted for her experience in international tax structuring, and in regulated sectors including energy and pharmaceuticals. Senior associate Tanel Molok represents clients in both misdemeanour and administrative proceedings.

Practice head(s):

Paul Künnap

Other key lawyers:

Kärt Anna Maire Kelder; Tanel Molok

Key clients

Vienna Insurance Group

Boku Inc

Bite Group

MDDP

TGS Baltic

TGS Baltic primarily handles tax disputes, drawing on its extensive expertise in tax litigation. The team also handles a range of day-to-day advice for corporates, including VAT and income tax. Helmut Pikmets is well known for his disputes work, having appeared before the Estonian Supreme Court in tax cases. Senior associate Sergei Jegorov is noted for his corporate taxation, risk and restructuring advice.

Practice head(s):

Helmut Pikmets

Other key lawyers:

Sergei Jegorov

Testimonials

‘Speaking from an international perspective, I can rate the service quite good. The leading tax lawyer in TGS is Helmut Pikmets who has communication channels with the Estonian Tax and Customs Board which, combined with his experiences with numerous cases from the past, he can draw from to provide advice with reasonably accurate expectations of how the tax authorities would react to legally unclear cases.

‘Helmut Pikmets: Has great expertise and some informal ties to the Tax Board to be able to anticipate their governing operating principals for decisions without a clear precedent. Available for calls and meetings at odd hours to get things done.’

‘TGS Baltic tax team has been a most valued partner in dealing with our complicated international tax matters where we used their outstanding competencies and knowledge.’

‘We have had pleasure to work with absolutely the best tax professionals that we could get in Estonia. Helmut Pikmets and Sergei Jegorov are both excellent team players that fit into our team right from that beginning. We consider it really important that Helmut and Sergei are both well known tax practitioners with long history of dealing with this kind of complicated tax matters what we were facing.’

Key clients

Luminor

Tallink Group

Swedbank

Imatra Elekter

Baltic Ground Services

HKScann

Work highlights

  • Advised US Nasdaq-listed Opera group on the tax aspects of signing a share purchase agreement for the acquisition of banking-as-a-service provider PocoSys and its sister company, EU-licensed Pocopay, from Poco Holding.
  • Advising Lietuvos Energija’s gas trading subsidiary Lietuvos energijos tiekimas on tax matters regarding setting up a gas supply in Estonia.
  • Acting for Circle K in filing a complaint to the European Commission with regard to potential unlawful state aid deriving from the statistics trading system enforced by the Estonian Liquid Fuel Act.

WALLESS (former Derling Primus)

WALLESS (former Derling Primus) is highly recommended for taxation disputes and for advisory work concerning private equity and investments funds. The team also handles matters arising from M&A and corporate restructuring. Practice head Rolan Jankelevitsh has extensive experience of matters relating to M&A transactions, and has advised on legislation introducing a digital services tax in Estonia. Priit Raudsepp previously worked for the Estonian tax authority, and now brings that experience to bear defending criminal tax disputes. He is also key to the group’s international taxation work.

Practice head(s):

Rolan Jankelevitsh

Other key lawyers:

Priit Raudsepp

ATTELA Advokaadibüroo

Specialist tax firm ATTELA Advokaadibüroo has extensive experience of both domestic and international taxation law. Marek Herm is an expert on the ramification of bilateral tax treaties; he jointly heads the team with Marko Saag and Kaspar Lind, who is an expert in anti-money laundering and tax evasion disputes. The team is especially recommended for clients dealing with cryptocurrency and blockchain technologies.

Practice head(s):

Marek Herm; Marko Saag; Kaspar Lind

Other key lawyers:

Madis Uusorg

Testimonials

‘The team constantly participates in educational activities and are often involved in preparation of regulative initiatives of tax law. At the same time all partners and associates of the law firm have excellent knowledge in other areas of civil law. ’

‘I would specifically point out Mr. Marek Herm as an exceptional partner in this law firm. He has a thorough knowledge in tax law matters. He has an ability to grasp clients’ problems very fast and to provide a comprehensive solution concentrating not only on the essence of the problem, but also on the solution that would be the best suitable, bearing in mind the specific industry problematics of the client. His advice is always very valuable and foresighted.’

‘Problem solving and answering questions in a clear and concrete way.’

‘Madis Uusorg is thorough and detailed and has been able to explain the peculiarities of international taxation in the transport sector very well. Kaspar Lind has proposed practical and sensible solutions for structuring companies, taking into account both tax and business law aspects.’

‘The team’s wide knowledge of legal issues surrounding blockchain industry has been a great help to our business. The team has excellent experience in international tax and blockchain industry. ’

‘Our key contact is Marek Herm. We value his experience in both international and Estonian domestic matters. In our business, we sometimes need assistance in a very short notice. We have always managed to have it.’

‘We have used their services over the course of six years and are impressed with their grasp on how the tax law is applied realistically on a daily basis in court proceedings. In addition to that they have developed professional relations with the Tax and Customs authority which enable quick communications and results on smaller issues.’

‘I have worked with two team members of the firm. I have nothing, but positive things to say about their approach to the work. They are thorough, on time and available even in most demanding situations.’

‘Attorney-at-Law Marek Herm has been a trustworthy legal partner to us in corporate and tax matters. It has been interesting to observe the change of the tone of the tax officials when instead of our accountant they find themselves disputing with him. He is respected among tax people. Many of young tax officials have been his students.’

‘Partner Marek Herm stands out for his long term international tax background and expertise. His advice is concise and value-creating. His knowledge of the needs of innovative technology companies makes him a very useful adviser.’

Key clients

Amon

Orvium

Lightstreams

AS East-West Consulting

OÜ Vallaste & Partnerid

Work highlights

  • Representation of Vallaste & Partnerid in a landmark case regarding reclassification of service fees.
  • Advising Amon on receiving investments.
  • Assisting Orvium with raising funds, developing the platform and ongoing legal support to the platform which is now in operation.

Eversheds Sutherland Ots & Co

Eversheds Sutherland Ots & Co advises corporate clients on tax planning and on all dealings with the Estonian Tax and Customs Board, and represents those clients in audits and litigation. A key part of the team’s work is in tax planning for multinational companies with a presence in Estonia. The practice is recommended for employment-related issues such as fringe benefit taxation and double taxation. Toomas Pikamäe heads the team and has experience of excise duties, land tax and environmental duties.

Practice head(s):

Toomas Pikamäe

Key clients

E-Piim Tootmine AS

Tallinn City Government

Icosagen Cell Factory OÜ

Confido Healthcare Group OÜ

Eesti Keskkonnateenused AS

Tallinna Vesi AS

Oniar OÜ

Pharma Group OÜ

Terve Pere Apteek OÜ

Work highlights

  • Represented E-Piim Tootmine in a dispute with the Estonian Tax and Customs Board before the Supreme Court of Estonia.
  • Assisted Icosagen Cell Factory with license agreements with German and Czech entities.
  • Advised Confido Healthcare Group on the tax aspects of employing Swedish and Finnish doctors.

Glikman Alvin LEVIN

Given the strength of the firm’s disputes practice, the team at Glikman Alvin LEVIN is particularly recommended for tax litigation and audits, areas where Paul Keres is noted. Other strong suits include restructuring, tax related to investment properties, indirect taxation and complex tax arrangements and planning.

Magnusson

Magnusson stands out for its close communication with the firm’s offices in Russia, Scandinavia and the Baltic. Elvira Tulvik, who heads the team, has extensive experience providing regulatory advice, particularly relating to market entry and exit strategies, and handling the tax aspects of major multi-jurisdictional transactions. The practice also handles tax planning, audits, personal taxation, indirect taxation and day-to-day tax advice.

Practice head(s):

Elvira Tulvik

Testimonials

‘Magnusson is our long-term legal advisor and in recent years we have used them mainly in dispute resolution and tax related matters. We would characterize Magnusson as a trustworthy team of highly capable lawyers able to deliver on time. They are prompt in their responses and consistent in their work. Legal questions dealt with are always regarded in a business perspective and in line with our long-term business strategies which I find extremely important.’

Key clients

Saint-Gobain Estonia

FlixBus Polska

Bergé Automoción

Work highlights

  • Advising Bergé Automoción on entering the Baltic-Nordic market, both for theoretical advice describing the applicable regulations, and practical assistance with establishment, registrations and compliance.
  • Advising Saint-Gobain Group on the restructuring of its Estonian companies.
  • Advising FlixBus Polska on all aspects of market entry and the start of operations.

RASK Attorneys-at-Law

RASK Attorneys-at-Law is noted for its expertise in international tax law and in tax litigation. Practice head Villy Lopman has extensive experience representing clients in cases brought by state authorities, with a particular niche in advising local authorities on relations with state tax bodies.

Practice head(s):

Villy Lopman

Testimonials

‘RASK is a good firm. No matter how complex the matter, they react quickly and provide good legal solutions. Always a phone call away.’

‘Villy Lopman has been a reliable partner for me for years. Very competent in tax and administrative law. Provides clear and realistic outlook on things, keeps me updated at all times and offers good solutions.’

Key clients

Estonian Autosport Events MTÜ

Sihtasutus Bocuse d’Or Tallinn 2020

Kuressaare Hospital

Pärnu Sadam AS

KPMG Law in Estonia

Joel Zernask leads the full-service tax practice at KPMG Law in Estonia. Key areas of work include corporate tax advisory, VAT issues, M&A risk assessment and international tax structuring. The team has a particularly strong offering for cryptocurrency companies, and also handles restructuring and management incentive plans.

Practice head(s):

Joel Zernask

Key clients

Infortar

Eesti AGA

Capital Mill

Partners Group

Ekspress Grupp

Maag Grupp

Lidl Stiftung & Co. KG

BaltCap

Philip Morris

Stockmann

Laurus S.a.r.l.

Work highlights

  • Assisted Eesti Gaas with taxation regulation, VAT, excise, corporate and payroll taxes in Finland and in Latvia arising from the expansion of the business to those countries and structuring the business in the most tax optimal way.
  • Assisted Münchhausen with Indian withholding income tax matters, including tax advisory and compliance.

Advokaadibüroo PricewaterhouseCoopers Legal OÜ

Priit Lätt heads the tax team at Advokaadibüroo PricewaterhouseCoopers Legal OÜ, which can draw on the firm's tax advisory practice for expertise in restructuring, corporate tax and strategic advice. The department also handles tax litigation, often in cases with cross-border aspects.

TARK

TARK primarily focuses on transaction-related tax assistance, and also provides strategic and day-to-day advice and tax litigation. Other key areas of work include audits, distressed asset structuring and VAT issues. Allar Aru  and Hannes Küün  jointly head the practice; both have considerable experience handling tax-related aspects of transactions.