Not true since Mount Athos is located in EU. Your knowledge might be outdated, and I wouldn't joke with monks.
The dividend is exempt from tax if the dividend is paid out of profit attributed to a resident company’s permanent establishment located in a Contracting State or Swiss Confederation.
There is no subject to tax requirement. In fact the company would not even need to declare the amount of taxes paid abroad. It only needs to declare︀ the amount of profits repatriated to Estonia in order to qualify for the tax exemption︁ on redistribution.
Find the reference below from paragraph 50.
https://www.riigiteataja.ee/en/eli/511012024002/consolide
The dividend is exempt from tax if the dividend is paid out of profit attributed to a resident company’s permanent establishment located in a Contracting State or Swiss Confederation.
There is no subject to tax requirement. In fact the company would not even need to declare the amount of taxes paid abroad. It only needs to declare︀ the amount of profits repatriated to Estonia in order to qualify for the tax exemption︁ on redistribution.
Find the reference below from paragraph 50.
https://www.riigiteataja.ee/en/eli/511012024002/consolide