CFC as an Estonian e-resident


as an e-resident of Estonia, and a permanent traveler, would I be affected by CFC? Meaning, is CFC something where

a) Estonia would tell a certain country (maybe the country where most of my clients are) that I have a company in Estonia


b) I would tell the tax authorities in the country where I happen to be that I have a company in Estonia?

I think it’s b, and since I am not a resident anywhere, CFC would basically not affect me (except at the point where I decide to withdraw dividends, but I am planning to defer that for a while).


In our opinion Estonian company can not be treated as your CFC company, becuase Estonia does not offer 0% tax rate - tax rate is 20% and you pay the tax in the event if you distribute profits to company shareholders.

0% is not tax rate - Tax rate is 20% , and from 14-20% if you regular distribute profits.
This is only shifting of paying tax to the time, when you distribute profits.

If you can to obtain legal opinion, we can preapre it for you.