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Estonian CIT 2026 — when it pays off, and when it doesn't

by BCR GROUP
  • #CIT
  • #taxes
  • #Estonian CIT

The core idea

Estonian CIT (officially: ryczałt od dochodów spółek — note: this is a Polish tax regime, not Estonian) is only paid when the company distributes profit to shareholders. As long as you reinvest, there is no CIT. Rates: 10% for small taxpayers, 20% for the rest — applied to the dividend amount paid out.

Who can opt in

  • a capital company or limited partnership,
  • shareholders are exclusively individuals,
  • less than 50% of revenue from passive sources (rent, interest, royalties),
  • at least 3 people on employment contracts,
  • no holdings in other companies.

Each of these conditions tends to become a trap. The most common issue: a shareholder also runs a JDG (sole proprietorship) that invoices their own company. After moving to Estonian CIT, that often qualifies as "passive income".

When it pays off

  • The company retains most of its profit (for investment, growth).
  • Shareholder salaries are low or absent.
  • The company doesn't distribute dividends more than once every 2–3 years.

When it doesn't

  • A shareholder draws money every month — every payout is taxed as a dividend.
  • You plan to sell shares within 2 years — some benefits are clawed back retroactively.
  • You have heavy depreciation — under Estonian CIT it effectively "disappears".

The trap nobody talks about

Exiting Estonian CIT is almost never tax-neutral. You have to compute transformation income — that's often an unpleasant surprise.

Before deciding, run a 3-year projection with your accountant. If you'd like our team to do it — leave your details in the form.

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