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HMRC internal manual

Double Taxation Relief Manual

Estonia: Underlying Tax

  1. Documents needed to support the underlying tax claim

The accounts showing the profits out of which the dividend was paid and details of the distribution tax will be required by the Underlying Tax Group.

  1. Distribution tax 

Estonian companies are not subject to tax on their income; instead they are subject to a distribution tax at a rate of 26/74 on payments including dividends. This is wholly set against the United Kingdom corporation tax on the gross dividend in accordance with SP 3/01. An example is shown below.

Net distribution 100
Distribution tax 26/74 35.14
Gross dividend 135.14
Tax rate 26%