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0% corporate tax while profit stays in the company: Estonia and Latvia

Estonia and Latvia are the only EU countries where corporate profit is untaxed until it leaves the company - 0% on retained or reinvested profit, for companies of any size, indefinitely. The tax arrives only on distribution: 22% in Estonia, 20% in Latvia, with no further tax at the shareholder.

发布于 2026-07-16最后审阅 2026-07-16

Key facts

ItemEstoniaLatvia
Retained or reinvested profit0%0%
Distributed profit22% of the gross (≈28.2% of net)20% of the gross (≈25% of net)
Further tax at the shareholderNoneNone
Dividend withholding for non-residents0%0% (20% to blacklisted jurisdictions)
Optional regime from 2026-15% CIT + 6% PIT on dividends

[1][2][4][5]

What the deferral is worth

The regime is a compounding machine. A company earning €100,000 a year and reinvesting everything deploys the full €100,000 each year; a Lithuanian competitor at the standard 17% rate deploys €83,000. Over years of reinvestment the gap compounds - which is why the structure suits businesses that grow from retained earnings: product companies, asset builders, anything pre-exit. Estonia adds practical appeal: an OÜ can be formed and run entirely online through e-Residency.[3][6]

The deferral is not a rate cut. At distribution Estonia takes 22% and Latvia 20%. Against Lithuania’s 20.95% total for a small company (7% corporate + 15% dividend) the difference is small; against Lithuania’s two-year 0% start-up relief it can even be negative. The value is entirely in the timing: tax-free compounding until the year you choose to pay out.[1][4][6]

Latvia’s 2026 twist

From 2026 Latvia lets companies owned by individuals opt into an alternative: 15% corporate tax on distributable profit plus 6% personal income tax withheld on the dividend - roughly 20% combined, paid earlier but at a structure closer to a classical system. The default 0/20 regime remains.[4][5]

The catch

Everything that sneaks value out of the company is taxed like a distribution: fringe benefits, gifts, non-business costs. Directors’ fees paid by an Estonian company are taxable in Estonia regardless of where the director lives. And the big one: running an Estonian or Latvian company from another country can make it tax-resident there under place-of-effective-management rules, which deletes the whole regime. e-Residency is a login, not a tax residence.[1][2]

常见问题

Can profit stay untaxed in an Estonian company forever?

Yes - there is no deadline and no deemed distribution for ordinary retained profit. Tax arises only when profit is distributed or leaks out as fringe benefits or non-business expenses.

Which is cheaper at distribution - Estonia or Lithuania?

For a small company, Lithuania: 7% corporate tax plus 15% dividend tax is 20.95% in total, marginally below Estonia’s 22%. Estonia wins on everything retained; Lithuania wins slightly on everything paid out.

Does e-Residency make me or my company Estonian for tax purposes?

No. It is a digital identity for signing and filing. A company managed day-to-day from another country risks being tax-resident in that country, whatever its register says.

跨境结果取决于税务居民身份、受控外国企业规则和真实的经济实质 - 纸面架构是远远不够的。请参见下方的免责声明。

来源

本文引用的编号参考资料。法律链接至官方注册机构中的整合文本。

  1. 《所得税法》(Tulumaksuseadus),英文综合文本Riigi Teataja - 国家公报 · 法律
  2. 股息征税EMTA(税务和海关局) · 机构
  3. 电子商业登记局登记和信息系统中心 (RIK) · 注册登记
  4. 企业所得税法 (Uzņēmumu ienākuma nodokļa likums)likumi.lv - 拉脱维亚立法 · 法律
  5. 2026年税收与财务变更财政部 · 机构
  6. 《企业所得税法》(Pelno mokesčio įstatymas),综合文本e-seimas.lrs.lt - 法律法规注册局 · 法律

本指南仅提供一般性信息,不构成税务或法律咨询。税率和截止日期可能会有变动 - 在采取行动之前,请务必对照链接的法律和官方来源进行核实,或咨询持牌顾问。