THE 2025 ZERO-TAX RESIDENT’S PLAYBOOK FOR AN ESTONIAN OÜ

ActionMan

🗣️ Loud Newcomer
May 18, 2023
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(a.k.a. How to run an EU company, pay zero personal tax, invest globally, and be audit-proof)
Figured I’d drop this here since a few people keep DM’ing me in telegram about how I’m running a fully legit EU company, taking out six figures a month, investing globally for my PSP ventures, and somehow paying absolutely nothing in personal tax.
Spoiler: it only works if you live somewhere with 0% income tax or a territorial system that doesn’t care about foreign income (UAE in my case). If you’re sitting in Germany or Canada, forget it.

Step 1 – The Company​

  • Registered an OÜ in Estonia. later €150/month for accounting, annual report, and all the boring crap.
  • I’m the only shareholder and director, but I live in UAE so there’s no “effective management” in Estonia. This is important. no local footprint, no PE risk (Please spare me about the UAE PE nonsense, it doesn't apply, never will. UAE’s 9% CIT doesn’t apply because all OÜ income is foreign-sourced, this is literally spelled out in the Ministry of Finance’s guidance.).
  • Activity listed as “consulting + IT services” which basically covers anything digital.

Step 2 – Banking​

  • Bankfrick.
  • Soldo as a Backup and for cards.
  • Wio (good if you avoid P2P with no SOF to back it) /ENBD (great) in UAE for personal account (where the management fees land).
  • Everything happens online, never had to physically show up anywhere.

Step 3 – Getting Paid (The Real Trick)​

  • Signed a Management Services Agreement between me personally (UAE) and my Estonian OÜ.
  • Fee is set high because I’m “running” the business, €70k–€100k/month depending on revenue.
  • Every month I invoice the OÜ from my UAE address → OÜ pays me → deducts it as an expense.
  • Profit left in OÜ = close to zero → corporate tax in Estonia = 0%.
  • Personal tax in UAE = 0%.

Step 4 – What I Do With Leftover Profits​

I don’t drain 100%, I leave a chunk in the company for investments:
  • IBKR corporate for ETFs and stocks.
  • Kraken corporate for BTC/ETH/USDT.
  • Sometimes buy into EU/UK startups (mostly PSP businesses<20% stakes to keep it simple).
  • Looking at a foreign property deal via an offshore SPV owned by the OÜ.
All gains stay in the company and aren’t taxed until (if ever) I take them out as dividends.

Step 5 – Compliance Without Wanting to Die​

I hate paperwork, so:
  • Xero auto-generates and sends my monthly management fee invoice.
  • Quarterly “board meetings” = me talking to myself on Loom for 5 mins, transcript fed into trained Local LLM, output turned into minutes, signed with DocuSign, saved to Google Drive.
  • Annual asset register = export from IBKR/Kraken, dump into Excel, send to accountant.
  • VA in the Philippines (€200/month) handles all filing, chasing, storing docs. I just approve stuff on my phone/TG.

Step 6 – Audit? Why Not.​

Estonia doesn’t require it unless you get huge, but I pay a local CPA in UAE €1,200/year to do a private audit.
Not filed anywhere, just nice to have a clean file if anyone ever comes sniffing.

Costs:
  • Accounting: €150/month
  • VA: €200/month
  • Banking: basically free
  • Private audit: €1,200/year
  • Total = peanuts compared to the tax bill I’d have anywhere else in the EU.
Results:
  • Personal take-home: ~€840k/year, tax-free.
  • OÜ investment portfolio growing tax-free in the background.
  • 100% legal, zero drama, and enough documentation to make an auditor’s eyes bleed before they find anything wrong.

This is honestly one of the easiest setups I’ve done for one of my EU companies.
I’ve got other structures that are a lot more layered and… let’s just say they keep the best lawyers in town busy. Same for my clients, some setups take months and cross 4–5 jurisdictions.
But the point is, you don’t always need something complicated to get a rock-solid, legal, low-tax system running. Sometimes the simplest structure, done properly, will outperform the flashy ones.

That’s the whole thing. No shady nominee crap, no crypto-in-a-shoebox under the bed. Fully above board, just structured right.
If you’re in a 0% or territorial tax country and want EU credibility without EU taxes, Estonia is a monster if you know how to play it.
 
Great write up. Clear, practical, and refreshingly specific on costs, banking, and the paperwork rhythm.

I’ve implemented a lighter version of this: UAE residency, Estonian OÜ for B2B services, a management agreement to route active income, IBKR corporate for the treasury sleeve, and a tight SoW/TP pack.

The biggest friction I hit was underwriting around the management fee level and proving day to day control sits outside Estonia; a short form benchmarking memo and cleaner board minutes solved most of it.

One critical question: how are you defending a €70 - 100k monthly management fee as arm’s length without tripping GAAR/TP adjustments in Estonia or UAE corporate tax on the personal side, and what concrete evidence do you keep on file (time sheets, deliverables, benchmarking, ESR filings, local office/director) to make that stick with auditors and banks?
 
Great write up. Thanks for sharing an example of a fairly simple and practical setup.

I've seen a few people on this forum talk about PE in UAE, so am waiting for the typical "umm akshually....." comments lol.
 
Yeah, he management fee is where most people stumble, but I don’t just pull €70–100k/mo out of thin air. The agreement is structured like any TP sensitive related-party transaction in the EU. The scope of work is broad and specific. strategy, vendor and partner negotiations, compliance oversight, treasury allocation, client acquisition, essentially CEO, CFO, and COO functions rolled into one. To back that, I keep a short benchmarking memo on file comparing management/CEO compensation in the PSP and fintech sector, where packages of €500k–€2M annually are very normal, so the fee level is easily defensible as arm’s length.

On top of that, I maintain quarterly board minutes, deliverables logs, and management notes showing day-to-day control and decision-making sits outside Estonia, which closes off the hidden dividend angle. From the UAE side, the fee is foreign-sourced income received as a natural person, which falls outside the corporate tax scope and doesn’t trigger ESR filings. In practice, that pack of documents has been more than enough to wave off any audit style questioning, and it keeps both the Estonian and UAE sides airtight.
 
Haha yeah, give it 5 minutes and someone will crawl out with a 2,000-word thesis on why your PE in UAE is actually the end of civilization. Gotta love forum professors.
 

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