Comparison between Estonia, Luxemburg and Switzerland

TAX RATES	LUXEMBOURG	SWITZERLAND	ESTONIA
Corporate income tax rate	21 %	8,5% (federal) (7,83% effective)	20%
Branch tax rate	21%	8,5% (federal) (7,83% effective)	No
Capital gains tax rate	0% / 21%	0% / 8,5% (federal) (7,83% effective)	No (taxed only where there is a profit distribution)
Basis	Worldwide income	Worldwide income	Worldwide income
Participation exemption	Yes	Yes	The corporate income tax will not be charged on redistribution of dividends, if the underlying dividends are received from a subsidiary that is tax resident in an EEA member state or Switzerland and the Estonian parent holds at least 10% of the shares or votes of the parent company.
Loss relief	Indefinite	7 years	Unlimited
Carryforeward	No	No	No
Carryback	–	–	–
Double taxation relief	Yes	Yes	Yes
Tax concolidation	Yes	No	Yes
Transfer pricing rules	Yes	No	Yes
Thin capitalization rules	No (other than for the holding of participation)	No, but safe harbor rules apply	No
Controlled foreign company rules	No	No	No (regime applies only to individuals)
Tax year	Calendar year or fiscal year	Financial year	Calendar year
Advance payment of tax	Yes	No	No
Return due date	31 May	Varies	Monthly bases
Dividends	0% / 15%	35%	0%
Interest	0% / (15% in certain cases)	0% / 35%	0%
Royalties	–	0%	0% / 10%
Branch remittance tax	0%	0%	0%
Capital tax	No	0,001% – 0,5%	No
Municipal business tax	6,75% – 12%	Not available	No
Employment surcharge	7%	1,0-2,2%	0,8% – 1,6%
Net worth tax	0,5%	Up to 0,5%	No
Min net worth tax	Varies	No	No
Chamber of Commerce contributions	0,025% – 0,2%	–	No
Social security contributions	12,42% – 15,2%	0,25% – 4,2%	33%
Real estate tax	0,7% – 1%	Cantonal level tax	0,1% – 2,5%
Transfer tax	6% (+1% transcription tax)	0,15% / 0,3%	No
Specific registration duty	0,6% or 6% (+1% transcription tax)	–	16 000 € for VAT
Stamp tax	Varies	1% / 2,5% / 5%	Varies
VAT	17% or 14%, 8%, 3%, 0%	8%	20% / 9%

COMPARISON BETWEEN ESTONIA, LUXEMBURG AND SWITZERLAND