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%