Only those questions with an *asterisk* are included in the calculation of the Key Financial Secrecy Indicators (KFSI) and affect the FSI ranking. In most cases of questions with an *asterisk* the data cut-off point for this report is 30.09.2019.

The database reports below contain all of the data we used in the financial secrecy index and some more besides. It gives information on a maximum of 152 variables for each jurisdiction, including full references and sources, accessible by clicking on the jurisdiction (flag or name). For more information see ... https://www.financialsecrecyindex.com/PDF/FSI-Methodology.pdf

Publication date: 20th February 2020

Estonia (EE). Reporting Period: 2020

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KNOWLEDGE OF BENEFICIAL OWNERSHIP

01 Bank Secrecy
360  *Are there criminal sanctions, custodial sentencing or any other statutory sanctions for breaches of banking secrecy? Yes, there are fines for disclosing client's banking data to any third party, but no prison terms.
352  *To what extent are banks subject to stringent customer due diligence regulations (Old FATF-recommendation 5 / new FATF-recommendation 10)? Largely.
353  *To what extent are banks required to maintain data records of its customers and transactions sufficient for law enforcement (old FATF-recommendation 10 / new FATF recommendation 11)? Largely.
89  *Are banks and/or other covered entities required to report large transactions in currency or other monetary instruments to designated authorities? Yes
157  *Does the domestic administration have sufficient powers to obtain and provide banking information on request? Yes without qualifications.
158  *Are there no undue notification and appeal rights against bank information exchange on request? Yes, but some problems.

02 Trust and Foundations Register
204  *Are Trusts available? ONLY FOREIGN: Foreign law trusts can be administered, but no domestic trust law.
355  *Convention of 1 July 1985 on the Law Applicable to Trusts and on their Recognition ("Hague Convention") No
206  *Is any formal registration required at all? NEITHER, BUT NO DOMESTIC: Domestic law trusts cannot be created, but no registration of domestically managed foreign law trusts.
214  *Is registration data available online ('on public record') for up to 10 €/US$? Not applicable
234  *Are Private Foundations available? Yes
236  *Is any formal registration required at all? Yes
237  *Are the settlors/founders named? Yes, but a legal entity or nominee could be named.
393  *What information has to be registered for those who need to be named (above)? All names plus countries of residence plus either addresses or TINs or birthdates, passport or personal IDs, or incorporation numbers are always registered.
238  *Are the members of the foundation council named? Yes, but a legal entity or nominee could be named.
394  *What information has to be registered for those who need to be named (above)? All names plus countries of residence plus either addresses or TINs or birthdates, passport or personal IDs, or incorporation numbers are always registered.
239  *Is the enforcer/protector named? Unknown
395  *What information has to be registered for those who need to be named (above)? Unknown
240  *Are the beneficiaries named? Yes, but a legal entity or nominee could be named, or a class of beneficiaries is identified.
396  *What information has to be registered for those who need to be named (above)? Unknown
384  *Is it mandatory to update the identity of those related parties (e.g. founders, council members, etc.) that have to be registered? Yes
244  *Is registration data available online ('on public record') for up to 10 €/US$? Partial online disclosure for all private foundations (e.g. foundation name or registered number or address)

03 Recorded Company Ownership
470  *LO Record: Does the registration of domestic companies comprise legal owner's identity information? All LO: Yes, all companies require recording of all legal owners.
472  *LO Update: Is the update of information on the identity of legal owners mandatory? Yes
486  *What information has to be registered for those legal owners who need to be named (above)? All names plus countries of residence plus either addresses or TINs or birthdates, passport or personal IDs, or incorporation numbers are always registered.
471  *BO Record: Does the registration of domestic companies comprise beneficial owner's identity information? Yes, more than 25%. All companies require recording of all beneficial owners at threshold of more than 25% (FATF).
473  *BO Update: Is the update of information on the identity of beneficial owners mandatory? Yes
485  *What information has to be registered for those beneficial owners who need to be named (above)? All names plus countries of residence plus either addresses or TINs or birthdates, passport or personal IDs are always registered.
388  *Can a senior manager ever be registered as a beneficial owner (because no individual passed the threshold to be considered a beneficial owner)? No, even if the senior manager is registered (because no individual passed the threshold to be considered a beneficial owner), he/she is registered as such, but not as an ordinary 'beneficial owner'.

04 Other Wealth Ownership
416  *Real Estate Registry: Is there a central registry of domestic real estate publicly available online? ONLINE: Yes, there is a central registry of real estate open to the public and accessible online.
437  *Is legal ownership information of real estate available on public online record (up to 10 EUR/GBP/USD)? COST: Yes, legal ownership is always available but only at a cost of up to 10 EUR/GBP/USD.
487  *Is beneficial ownership information of real estate available on public online record (up to 10 EUR/GBP/USD)? No, beneficial ownership not always available online (up to 10 EUR/GBP/USD).
418  *Freeports: Are freeports/free trade zones/foreign trade zones/bonded warehouses promoted as places to store valuable assets (e.g. gold bullion, art, precious stones, jewelry, cash, antiquities, wines, cigars, cars)? Unknown
439  *Freeport Owners: Is information on legal and beneficial owners of assets stored in freeports/free trade zones/foreign trade zones/bonded warehouses always registered by a government agency, and sent to respective countries of residence of the owners? Unknown

05 Limited Partnership Transparency
269  *Are partnerships with limited liability available? Yes
476  *LO Record: Does the registration of domestic limited partnerships comprise information on the legal ownership of all partners? Yes, all partnerships require recording of all partners/legal owners of all partners.
479  *LO Update: Is the update of legal ownership information mandatory for all partners? Yes
483  *What information has to be registered for those legal owners who need to be named (above)? All names plus countries of residence plus either addresses or TINs or birthdates, passport or personal IDs, or incorporation numbers are always registered.
477  *BO Record: Does the registration of domestic limited partnerships comprise information on the beneficial ownership of all partners? Yes, all partnerships require recording of all partners’ beneficial ownership.
480  *BO Update: Is the update of beneficial ownership information mandatory for all partners? Yes
484  *What information has to be registered for those beneficial owners who need to be named (above)? All names plus countries of residence plus either addresses or TINs or birthdates, passport or personal IDs, or incorporation numbers are always registered.
481  *LO: Are partners/legal owners available on a public online record (up to 10 €/US$/GBP)? COST: Yes, information on partners/legal owners is always available but only at a cost of up to 10 EUR/GBP/USD.
482  *BO: Are partners' beneficial owners available on a public online record (up to 10 €/US$/GBP)? COST: Yes, beneficial ownership information about all partners is always online, but only at a cost of up to 10 EUR/GBP/USD.
272  *Is there an obligation to keep accounting data? Yes
273  *Are annual accounts submitted to a public authority? Yes
274  *Are annual accounts available on a public online record (up to 10 €/US$/GBP)? COST: Yes, annual accounts are always online but only at a cost of up to 10 EUR/GBP/USD.

LEGAL ENTITY TRANSPARENCY

06  Public Company Ownership
470  *LO Record: Does the registration of domestic companies comprise legal owner's identity information? All LO: Yes, all companies require recording of all legal owners.
472  *LO Update: Is the update of information on the identity of legal owners mandatory? Yes
486  *What information has to be registered for those legal owners who need to be named (above)? All names plus countries of residence plus either addresses or TINs or birthdates, passport or personal IDs, or incorporation numbers are always registered.
471  *BO Record: Does the registration of domestic companies comprise beneficial owner's identity information? Yes, more than 25%. All companies require recording of all beneficial owners at threshold of more than 25% (FATF).
473  *BO Update: Is the update of information on the identity of beneficial owners mandatory? Yes
485  *What information has to be registered for those beneficial owners who need to be named (above)? All names plus countries of residence plus either addresses or TINs or birthdates, passport or personal IDs are always registered.
475  *LO Online: Are companies' legal owners available on a public online record (up to 10 €/US$/GBP)? COST: Yes, legal ownership is always available but only at a cost of up to 10 EUR/GBP/USD.
474  *BO Online: Are companies' beneficial owners available on a public online record (up to 10 €/US$/GBP)? COST: Yes, beneficial ownership is always available but only at a cost of up to 10 EUR/GBP/USD.

07 Public Company Accounts
188  *Is there an obligation to keep accounting data? Yes
189  *Are annual accounts submitted to a public authority? Yes, there is an obligation to submit annual accounts for all types of companies.
201  *Are annual accounts available on a public online record (up to 10 €/US$/GBP)? COST: Yes, company accounts are always online but only at a cost of up to 10€/10$.

08 Country-by-Country Reporting
318  *CBCR: Are companies listed on the national stock exchange or incorporated in the jurisdiction required to comply with a worldwide country-by-country reporting standard? Yes, partial disclosure for both extractives and banking sector.

09 Corporate Tax Disclosure
419  *CBCR: Is there a local filing requirement of a global country-by-country reporting file (according to OECD’s BEPS Action 13) by large corporate groups (with a worldwide turnover higher than 750 million Euro) and local subsidiaries of foreign groups? OECD Legislation: Secondary mechanism is subject to restrictions imposed by OECD model legislation; or no secondary mechanism at all (only the domestic ultimate parent entity has to file the CbCR)
363  *Tax Rulings: Are unilateral cross-border tax rulings (e.g. advance tax rulings, advance tax decisions) available in laws or regulation, or in administrative practice? Yes
421  *Tax Rulings: Are all unilateral cross­border tax rulings (e.g. advance tax rulings, advance tax decisions) published online for free, either anonymised or not? SOME FOR FREE: Some unilateral cross­border tax rulings are published online for free.
561  *Mining contracts in law: Are all extractive industries mining contracts required by law to be disclosed? Not Applicable
562  *Mining contracts in practice: Are all extractive industries mining contracts published online in practice? Not applicable
563  *Petroleum contracts in law: Are all extractive industries petroleum contracts required by law to be disclosed? Not Applicable
564  *Petroleum contracts in practice: Are all extractive industries petroleum contracts published online in practice? Not applicable

10 Legal Entity Identifier
414  *LEI: Is the use of an annually updated Legal Entity Identifier (LEI, developed under the guidance of the Financial Stability Board, FSB) mandatory for all companies? No
415  *LEI: Is the use of an annually updated Legal Entity Identifier (LEI, developed under the guidance of the Financial Stability Board, FSB) mandatory for some financial market operators and/or asset classes? Yes, but only for trading in "Over the Counter" (OTC) derivatives.
420  *LEI: Is the use of an annually updated LEI mandatory for identification of reporting financial institutions (pursuant to the Common Reporting Standard (CRS), as referred to in the CRS commentaries, page 97, section I, subpara A (3))? No

INTEGRITY OF TAX AND FINANCIAL REGULATION

11 Tax Administration Capacity
317  *Large Taxpayer Unit: Does the tax administration operate one central unit for large taxpayers (large taxpayer unit, LTU)? Yes
400  *HNWI Unit: Does the tax administration operate one central unit dedicated to the taxation of High Net Worth Individuals (HNWI)? No
401  *Individual TIN: Are all natural persons subject to personal income tax provided with unique and mandatory Taxpayer Identifier Numbers (TINs) which are mandatory for filing their tax returns? Yes
402  *Corporate TIN: Are all legal persons subject to corporate income tax provided with unique and mandatory Taxpayer Identifier Numbers (TINs) which are mandatory for filing their tax returns? Yes
403  *Taxpayers reporting schemes: Are taxpayers required to report at least annually on certain tax avoidance schemes they have used? No.
404  *Tax advisers reporting schemes: Are tax advisers (who help companies and individuals to prepare tax returns) required to report at least annually on certain tax avoidance schemes they have sold/marketed (if applicable)? Yes, but the schemes are only reported to the tax administration (they are not published).
405  *Taxpayers reporting uncertain tax positions: Are taxpayers required to report at least annually on details of uncertain tax positions for which reserves have been created in the annual accounts? No.
406  *Tax advisers reporting uncertain tax positions: Are tax advisers required to report at least annually on details of uncertain tax positions for which reserves have been created in the annual accounts of the companies they advised? No.

12  Consistet Personal Income Tax
435  *Personal Income Taxation: Is there a personal income tax with a comprehensive scope? Yes, there is a uniform personal income tax regime with a worldwide income tax base.
374  *CRS MCAA Voluntary Secrecy: Has the jurisdiction chosen “voluntary secrecy” (listed under the MCAA’s Annex A to prevent receiving information) or is otherwise not compliant with basic confidentiality requirements to receive information? No
489  *Citizenship-By-Investment and Residency-By-Investment Schemes: Can individuals acquire citizenship, passports or residency status in exchange for an investment or another payment without a prior requirement to spend more than 2 years in the jurisdiction? Yes

13 Avoids Promoting Tax Evasion
552  *Legal Person, Resident, Independent Party: Dividends Exemption.
555  *Legal Person, Resident, Related Party: Dividends Exemption.
558  *Natural Person, Resident (UR): Dividends Exemption.
553  *Legal Person, Resident: Interest Exemption.
559  *Natural Person, Resident (UR): Interest Credit.

14 Tax Court Secrecy
407  *Are all court proceedings on criminal tax matters openly accessible to the public, and the public cannot be ordered to leave the court room by invoking tax secrecy, bank secrecy, professional secrecy or comparable confidentiality rules? No
408  *Are all court proceedings on civil tax matters openly accessible to the public, and the public cannot be ordered to leave the court room by invoking tax secrecy, bank secrecy, professional secrecy or comparable confidentiality rules? No
409  *Is the full text of judgements / verdicts issued by criminal tax courts published online for free, or for a cost of up to 10 €/US$/GBP?? Cost/Anonym: Yes, full text of verdicts is always online but only at a cost of up to 10 €/US$/GBP, or it is always available for free but in anonymised form.
410  *Is the full text of judgements / verdicts issued by civil tax courts published online for free, or for a cost of up to 10 €/US$/GBP? Cost/Anonym: Yes, full text of verdicts is always online but only at a cost of up to 10€/US$/GBP, or it is always available for free but in anonymised form..

15 Harmful Legal Vehicles
488  *Does the jurisdiction issue or accept circulation of large banknotes/cash bills of its own currency (of value greater than 200 EUR/GBP/USD)? Yes
172  *Are bearer shares available? No, bearer shares are not available/not circulating.
184  *Protected Cell Companies/Series LLCs? No
224  *Are trusts with flee clauses prohibited? No

16 Public Statistics
426  *Trading goods: Is data on bilateral trade in goods (equivalent to UN Comtrade, and/or more disaggregated version) published in a timely fashion online for free through the relevant international organisation? Yes
427  *Trading services: Is data on bilateral trade in services (equivalent to UNCTADstat, and/or more disaggregated version) published in a timely fashion online for free through the relevant international organisation? Yes
428  *Trading financial services: Is data on trade in financial services (equivalent to IMF's balance of payment statistics, and/or more disaggregated) published in a timely fashion online for free through the relevant international organisation? Yes
429  *Offshore trade: Is bilateral data on transit/merchanting trade (similar to Hong Kong's offshore trade in goods) published in a timely fashion online for free? No
430  *IMF CPIS: Does the jurisdiction participate in the Coordinated Portfolio Investment Survey (CPIS) of the IMF and is the data published in a timely fashion online for free through the relevant international organisation? Yes
431  *IMF CDIS: Does the jurisdiction participate in the Coordinated Direct Investment Survey (CDIS) of the IMF and is the data published in a timely fashion online for free through the relevant international organisation? Yes
432  *BIS Locational: Does the jurisdiction participate in the locational banking statistics of the Bank for International Settlements (BIS), and is the data published in a timely fashion online for free through the relevant international organisation? No
433  *National Bilateral BIS: Is data on national bilateral banking liabilities published with country level breakdowns of the countries of origin (equivalent to Bank for International Settlements (BIS) locational banking statistics, tables A5-A7)? No
434  *CBCR Aggregates: Are global country-by-country reporting aggregates pursuant to OECD BEPS Action 13 (Annex III of Chapter V, pages 29-30) of all multinational corporate groups with domestic headquarters, published in a timely fashion online for free? No
425  *CRS Aggregates: Are aggregates of the data reported under CRS published in a timely fashion (without identifying any specific person or account) online for free? Unknown

INTERNATIONAL STANDARDS AND COOPERATION

17 Anti-Money Laundering
335  *FATF Performance: Overall Non-Compliance Score of FATF-standards in Percentage (100% = all indicators rated non-compliant/low level of effectiveness; 0% = all indicators rated compliant or highly effective). 37.5

18 Automatic Information Exchange
150  *CRS MCAA Signed: Has the jurisdiction signed the Multilateral Competent Authority Agreement (MCAA) to implement the OECD’s Common Reporting Standard (CRS) (the CRS-MCAA)? 2019: Signed the MCAA and committed to exchange information in or before 2019
376  *CRS Pilot: Is the jurisdiction engaging (or has expressed interest in participating) in any Pilot Project, that involves partnering up a developed country with a developing country to assist implementing the CRS? No
371  *CRS MCAA Dating Number: Number of meaningful Activated AEOI relationships (under the MCAA) published by the OECD as of October 2019? 96
372  *CRS MCAA Refusal: Has the jurisdiction refused to engage in AEOI with any co-signatory of the MCAA even though that co-signatory complies with domestic law and confidentiality provisions? No
374  *CRS MCAA Voluntary Secrecy: Has the jurisdiction chosen “voluntary secrecy” (listed under the MCAA’s Annex A to prevent receiving information) or is otherwise not compliant with basic confidentiality requirements to receive information? No
377  *CRS Additional Conditions: Has the jurisdiction imposed additional conditions to engage in AEOI (beyond those required by the MCAA) such as amnesty programs, market access, etc.? No
566  *OECD’s Model Mandatory Disclosure Rules: Has the jurisdiction implemented the OECD’s model mandatory disclosure rules for CRS avoidance arrangements and opaque offshore structures published in 2018? Yes
567  *Wider-wider approach: Is the jurisdiction applying the “wider-wider” approach (information is collected and reported to local authorities about all non-residents, regardless if resident in a participating jurisdiction or not)? Yes
568  *Bitcoins within CRS scope: Does the jurisdiction include entities issuing, trading, exchanging or holding cyrpto-currencies (eg bitcoins) as "financial institutions" that are required to report information pursuant to the CRS? No
569  *Use beyond tax: Has the jurisdiction signed the Global Forum's Punta del Este Declaration of November 2018, or is it authorising to use the information received pursuant to the CRS for non-tax purposes (eg corruption, money laundering)? No

19 Bilateral Treaties
309  *Amended Council of Europe / OECD Convention on Mutual Administrative Assistance in Tax Matters (Tax Convention) Yes, party to the Amended Convention.
143  *Bilateral Treaties for Information Exchange Upon Request: Number of Double Tax Agreements (DTA) or Tax Information Exchange Agreements (TIEAs) with provisions for 2002 OECD-style information exchange? Uknown

20 International Legal Cooperation
309  *Amended Council of Europe / OECD Convention on Mutual Administrative Assistance in Tax Matters (Tax Convention) Yes, party to the Amended Convention.
33  *UN Convention Against Corruption Yes
35  *UN International Convention for the Suppression of the Financing of Terrorism Yes
36  *UN Convention Against Transnational Organized Crime Yes
310  *Will mutual legal assistance be given for investigations, prosecutions, and proceedings (Old FATF-recommendation 36 / new FATF-rec 37)? Largely.
311  *Is mutual legal assistance given without the requirement of dual criminality (only old FATF recommendation 37)? Largely.
312  *Is mutual legal assistance given concerning identification, freezing, seizure and confiscation of property (FATF recommendation 38)? Largely.
313  *Are countries effectively and constructively executing extradition requests in relation to money laundering and terrorist financing, without undue delay (FATF recommendation 39)? Largely.
314  *Is the widest range of international cooperation rapidly, constructively and effectively provided by competent authorities to their foreign counterparts in relation to anti-money laundering and terrorist financing (FATF recommendation 40)? Fully.
469  *International co-operation delivers appropriate information, financial intelligence, and evidence, and facilitates action against criminals and their assets (Immediate Outcome 2 of the effectiveness assessments under FATF 2013/2017 methodology)? Not applicable

ANCILIARY DATA

 Global Scale Weight
581  Assets, 2018 (US$, filtered following Zoromé, 2008) 2058716928
582  Portfolio assets, 2018 (US$) 14741161984
583  Portfolio liabilities, derived, 2018 (US$) 3048935424
354  Global scale weight (share of jurisdiction's exports of financial services on the global total) 0.01920803822577
576  Final exports of financial services (true or extrapolated), 2018 (US$) 100687128
579  Global total of final exports of financial services (true or extrapolated), 2018 (US$) 523320885248
577  Exports of financial services, 2018 (US$) 100687128
580  Exports of financial services, 2017 (US$) 137159760

 Other data - Basic
365  World Region Europe
2  Jurisdiction Status Independent Sovereign State
4  Population 1569174
30  Legal System Civil Law
367  OECD membership Yes, OECD member
573  OECD membership - year of accession 2010
368  EU membership Yes, EU member
369  G20 membership Yes, G20 member
578  G24 membership No
586  G77 membership No

 Other data - Economy
575  GDP (current US$) 30732144640
15  GDP p.c. (current US$) 28700
366  Income Classification (Worldbank) High income
21  Income distribution: GINI coefficient 39.5
359  Income distribution: Palma ratio 0.0573613792657852
105  Number of companies with limited liability 175574
350  Number of private foundations 617
493  Number of partnerships with limited liability 3499