Estonia
maksu määramine hindamise teel — assessment of tax by estimation
Findings at a glance
- Traceability of the calculation
- Completeness of the data basis
- Business-specific benchmark
- Requirements for counter-evidence
- Burden of proof and its reversal
4× exceeded · 1× met
Traceability of the calculationexceeded
The methods of estimation and the evidence used must be set out in the notice of assessment.
CitationMaksukorralduse seadus § 94 lg 2
What we provideEvery figure is traceable down to the individual document. The chain of calculation can be walked in both directions — from the result to the document and back.
Completeness of the data basisexceeded
Estimation is based on the information collected in the case, on the business indicators and costs of the taxable person, and on comparisons with other similar tax cases.
CitationMaksukorralduse seadus § 94 lg 2
What we provideA full census across all accounts, suppliers and product groups. No sampling is used; 100 per cent is the upper limit and cannot be exceeded by any method.
Requirements for counter-evidenceexceeded
Estimation is permitted only where it is not possible to establish the facts by any other evidence.
CitationMaksukorralduse seadus § 94 lg 1
What we provideA closed system: purchasing, production, masses, unit counts, sales channel and revenue support one another. A single incorrect figure shows up against the others.
Further information — 2 axes
Business-specific benchmarkexceeded
Alongside the taxpayer’s own indicators, comparisons with other similar tax cases are expressly permitted.
CitationMaksukorralduse seadus § 94 lg 2
What we provideThe calculation rests on the recipes and quantities of the audited business, not on an industry average.
Burden of proof and its reversalmet
Estimation is permitted where the written evidence is incomplete, insufficient or unreliable, has been destroyed or is missing.
CitationMaksukorralduse seadus § 94 lg 1
What we provideThe evidence is prepared so that the reversal of the burden remains traceable and the counter-evidence engages with the calculation, not with the objection.