Page 28 - Central and Eastern European Transfer Pricing Review

28 | CEE Transfer Pricing Review

Other recent Advance pricing
developments arrangements
We are not aware of any planned What APA options are available,
signifcant developments in the transfer if any?
pricing regulations.
APAs are currently not available.
Discussions regarding possible APA
rules have taken place. Is there a fling fee for APAs?
Not applicable.
Tax treaty/double tax Does the tax authority publish APA
resolution data either in the form of an annual
report or through the disclosure of
What is the extent of the double tax data in public forums?
treaty network?
Not applicable.
The double tax treaty network of Estonia
is extensive, with 50 treaties altogether. Please provide some information
on how successful the APA program
If extensive, is the competent is and whether there are any known
authority effective in obtaining diffculties?
double tax relief?
Not applicable.
Almost always.
When may a taxpayer submit an Language
adjustment to competent authority? In which language or languages
No formal rules. Basically anytime within can documentation be fled?
3 years of the submission of the tax
return on the adjusted period. The documentation may be presented in
a foreign language, but the tax authority
May a taxpayer go to competent may request that they be translated into
authority before paying tax? Estonian.
Yes, but no formal rules.

KPMG in Estonia

Maike Leppik
Tel: +372 66 76 803
Email: mleppik@kpmg.com

As email addresses and phone numbers
change frequently, please email us at
transferpricing@kpmg.com if you are unable
to contact us via the information noted above.
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