Estonia's Ministry of Finance has published the synthesized texts of the tax treaties with Lithuania, Norway, and Spain as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.
The MLI applies for the 2004 Estonia-Lithuania tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the 1 January 2023; and
- with respect to all other taxes levied by the Contracting States, for taxes levied with respect to taxable periods beginning on or after 1 January 2023.
Notwithstanding the above, Article 16 of the MLI (Mutual Agreement Procedure) has effect for a case presented to the competent authority of a Contracting State on or after 1 May 2021, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.
The MLI applies for the 1993 Estonia-Norway tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the 1 January 2023; and
- with respect to all other taxes levied by the Contracting States, for taxes levied with respect to taxable periods beginning on or after 1 January 2023.
The MLI applies for the 2003 Estonia-Spain tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the 1 January 2023; and
- with respect to all other taxes levied by the Contracting States, for taxes levied with respect to taxable periods beginning on or after 1 January 2023.
MLI synthesized texts of Estonia's tax treaties can be found on the Ministry of Finance MLI webpage.