We advised a client – co-owner of a company with their spouse – on structuring a real estate investment involving the construction of an office building on jointly held private land. The aim was to allow the company to operate from the property without transferring ownership and without breaching the tax rules under Estonian CIT.
We developed a lease framework that reflected real financial flows between the company and the shareholders, accommodated the planned short-term rental period (up to 5 years), and anticipated the future sale of the entire property as a private asset. Our approach reduced tax risk and ensured that payments would not be treated as hidden dividends.
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