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加强爱沙尼亚税收制度的选择：爱沙尼亚共和国

2025-07-25 国际货币基金组织申明华

Estonia’s tax system relies heavily on consumption taxes, particularly VAT, with income taxes forming a relatively small portion of revenue. This structure, while efficient, faces challenges in revenue generation given its narrow base. The country is experiencing elevated defense spending needs and long-term pressures from population aging and climate mitigation, creating fiscal imbalances.

The tax mix in Estonia resembles that of European emerging market economies more than advanced economies, with indirect taxes accounting for 42% of tax revenue and direct taxes for 29%. Compared to European advanced economies and the Nordics, Estonia collects significantly less tax revenue (22% of GDP in 2023), with VAT efficiency being the highest in the EU/OECD. However, the low tax effort and wider tax gap (14% of GDP) indicate untapped revenue potential.

Key issues and recommendations include:

Personal Income Tax (PIT): The current system, with a high basic allowance and low statutory rate, leads to lower revenues and disincentives to work for middle-income earners. Options to strengthen PIT revenue include:
- Implementing a slightly more progressive structure, such as a two-rate system, which could improve work incentives and revenue mobilization.
- Exploring revenue-neutral options like increasing the tax rate or lowering the basic allowance.
Corporate Income Tax (CIT): Estonia’s Distributed Profit Tax (DPT) system, while simple and efficient, has limitations in revenue generation. Options to strengthen CIT revenue include:
- Improving the current DPT design with a higher statutory rate.
- Transitioning to a standard CIT system with provisions like an Allowance for Corporate Equity (ACE) to maintain competitiveness while broadening the tax base.
- Exploring alternative rent taxes for efficiency gains.
Value-Added Tax (VAT): Estonia’s VAT system is efficient, but further revenue can be generated by:
- Streamlining remaining VAT exemptions to broaden the tax base.
- Resisting the proliferation of reduced rates and exemptions as statutory rates increase.
- Strengthening tax compliance through measures like mandatory invoice declaration and expanding e-invoice coverage.
Property Taxes: Estonia lacks a modern property tax system, relying solely on a land tax with widespread exemptions. Options to introduce a more comprehensive property tax include:
- Limiting exemptions on residential land.
- Developing a fiscal cadaster to ensure fair taxation based on property value and use.
- Implementing a flat-rate, value-based property tax with minimal exemptions and uniform treatment of business and residential property.

Overall, Estonia should consider a comprehensive review of its tax system to make it more robust, diversified, and capable of addressing current and future spending pressures while maintaining competitiveness.

IMF Selected Issues PaperEuropean DepartmentOptions to Strengthen the Tax System in EstoniaPrepared by Irina Bunda and Tibor HanappiAuthorized for distribution by Vincenzo GuzzoJuly 2025IMF Selected Issues Papersare prepared by IMF staff as background documentation for periodicconsultations with member countries.It is based on the information available at the time it wascompleted on June 23, 2025. This paper is also published separately as IMF Country Report No 25/182.ABSTRACT:Estonia’s tax mix has been traditionally reliant on consumption taxes—especially VAT—whereasincome taxes are a relatively small share of revenue. Recent and expected changes will further shift the taxburden in this direction. Consumption taxes are less distortive than income taxes, but higher spending needsmay require a broader revenue base, reaching untapped potential. This Selected Issues Paper discussesalternative broad-based, growth-friendly options on how to strengthen income, VAT, as well as property taxes.Options to strengthen revenues include (i) addressing the personal income tax revenue (PIT) shortfall from theintroduction of a uniform allowance by considering revenue neutral options, i.e., calibrate the basic allowance,the tax rates, and/or the tax brackets subject to the intended degree of progressivity; (ii) improving the capacityof the tax administration to analyze income statements and exploring alternative corporate income tax (CIT)regimes that would preserve the competitiveness of the current system while reaching a broader tax base; (iii)streamlining remaining VAT exemptions to broaden the tax base; and (iv) limiting exemptions on residentialland and taking steps to introduce a modern tax on immovable property by developing a fiscal cadaster toensure fair taxation based on value and use of property.RECOMMENDED CITATION:Bunda, Irina and Tibor Hanappi, 2025, “Options to Strengthen the Tax System inEstonia,” IMF Selected Issues Paper(SIPEA/2025/102), JulyH21;H22;H24; H25; H26; H27; H3Public finance, Tax policy, Tax systems, Corporate income tax,Consumption taxes, Cost of capital, Economic rent, Income andcapital gains taxes, Income distribution, Income tax systems,Personal income, Rate of return, Tax administration, Europe, Balticstates.ibunda@imf.org;thanappi@imf.org JEL Classification Numbers: Keywords:Author’s E-Mail Address: Options to Strengthen the TaxSystem in EstoniaRepublic of EstoniaPrepared by Irina Bunda and Tibor Hanappi REPUBLIC OF ESTONIASELECTED ISSUESApprovedByEuropean DepartmentPrepared ByIrina BundaandTibor HanappiOPTIONS TO STRENGHTEN THE TAX SYSTEM IN ESTONIAA. Introduction __________________________________________________________________________2B. Tax Mix, Effort and Potential in Estonia________________________________________________5C. Benchmarking the Estonian Tax System against Best Practices _______________________7D. Labor Taxation ______________________________________________________________________ 10E. Business Income Taxation ___________________________________________________________ 14F. Value-Added Tax ____________________________________________________________________ 19G. Property Taxes ______________________________________________________________________ 21H. Conclusion__________________________________________________________________________ 25BOXES1. Main Changes to Tax System Introduced in 2024-26__________________________________32. Income Taxation: Efficiency-Equity Trade-Off _________________________________________83. Property Taxation in Estonia ________________________________________________________ 22FIGURES1. Discussion of Personal Income Tax Reform Scenarios _______________________________ 13References_____________________________________________________________________________ 26CONTENTS 2INTERNATIONAL MONETARY FUNDOPTIONS TO STRENGHTEN THE TAX SYSTEM INESTONIA1Estonia’s tax mix has been traditionally reliant on consumption taxes—especially VAT—whereasincome taxes are a relatively small share of revenue. Recent and expected changes will further shift thetax burden in this direction. Consumption taxes are less distortive than income taxes, but higherspending needs may require a broader revenue base, reaching untapped potential. This Selected IssuesPaper discusses alternative broad-based, growth-friendly options on how to strengthen income, VAT,as well as property taxes. Options to strengthen revenues include (i) addressing the personal incometax revenue (PIT) shortfall from the introduction of a uniform allowance by considering revenueneutral options, i.e., calibrate the basic allowance, the tax rates, and/or the tax brackets subject to theintended degree of progressivity; (ii) improving the capacity of the tax administration to analyzeincome statements and exploring alternative corporate income tax (CIT) regimes that would preservethe competitiveness of the current system while reaching a broader tax base; (iii) streamliningremaining VAT exemptions to broaden

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