Estonian CIT does not exempt from transfer pricing obligations

The Supreme Administrative Court ruled on February 17, 2026, regarding the obligation of taxpayers under the Estonian CIT to apply transfer pricing regulations. The taxpayer received an unfavorable individual interpretation from the Director of the National Tax Information, which was upheld by the WSA in Poznań. The case focused on whether provisions concerning transfer pricing documentation and symmetrical adjustments apply to taxpayers subject to the Estonian CIT, despite the lack of explicit references in the relevant chapter of the CIT law.