On 28 December 2018, Estonia published the Income Tax Amendment Act of 12 December 2018 in the Official Gazette. The main measures of the Act provide for the implementation of the EU Anti-Tax Avoidance Directive (ATAD). The measures are summarized as follows:

GAAR

• A new general anti-avoidance rule (GAAR) based on ATAD is introduced, which includes that an arrangement or a series of arrange…