For now, the tax office mainly checks whether companies using Estonian CIT have met the formal requirements, it does not focus on tax settlement – we read in “DGP”. Data from the Ministry of Finance show that the tax office primarily examines whether companies correctly chose the lump sum tax, commonly known as Estonian CIT, and whether they met the conditions when applying it.
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Hundreds of irregularities in the Estonian CIT
The newspaper quotes data from previous inspections. It follows from them that in the period from 2022 to mid-2025, the tax office found that many companies incorrectly chose this form of taxation. “He stated this the most, 642 times, after verifying the notifications on the selection of the lump sum (ZAW-RD). As many as 345 times, he stated that it had been submitted incorrectly,” says “DGP”.
In 99 cases, the tax office found that the company had incorrectly switched to Estonian CIT during the year, and in 424 cases the companies did not meet the conditions regarding this form of business, shareholder structure, employment, amount of passive income or non-application of IAS.
The newspaper notes, however, that the tax office rarely conducts classic audits in the field of Estonian CIT. “From the beginning of 2025 to March 2026, it initiated only 40 customs and tax inspections. At the same time, it completed 71 such inspections and showed losses of almost PLN 42 million for 64 taxpayers,” he emphasizes.
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In 2025, almost 20,000 companies submitted CIT-8E declarations. taxpayers, the vast majority of which were limited liability companies.
What is Estonian CIT? This is a system in which the company does not pay income tax (CIT) during the year or when generating profits on a current basis. Tax liability arises only when profit is paid to partners in the form of dividend. In the case of distribution of profits, the total tax paid by the company and the partner is lower than in the standard model. To benefit from Estonian CIT, a company must meet specific conditions, including: employ an appropriate number of employees and do not hold shares in other companies.
