Ask HN: Founders of estonian e-businesses – is it worth it?
Hey there,
I'm currently considering opening an Estonian e-business for a small SaaS project. As somebody from Germany, establishing a company is a bit tedious and bureaucratic. Now I've come across the Estonian e-residency program and the option to run a business there. I don't care so much about the tax implications, but more about the bureaucracy aspect. It all sounds quite good. But marketing is marketing and real life often is something else. So, long story short: I would be happy if somebody could share their real-life experiences. Was it/is it worth it? Are there any pitfalls?
Thanks!
64 comments
[ 4.2 ms ] story [ 236 ms ] threadFocus on your business, open the smallest and simplest entity you can to validate your product before spending time and money optimizing or scaling things. That being said, I’m familiar with GmbHs in Germany and I would advise against going this route unless funding is available. Try a sole proprietorship instead if possible.
edit: just stumbled upon this really good blog post about the topic, in case anyone is interested: https://eidel.io/posts/estonias-e-residency-is-awesome-and-s...
Skimmed this thread and I'm quite surprised how few people are aware of the permanent establishment problem.
Quick primer on the permanent establishment problem: You would technically have to pay taxes for your company in the place you're living (not Estonia). For example, if you're living in Germany, your Estonian OÜ would technically have to file for German taxes, too, because it's being run from Germany and it now has a permanent establishment in Germany.
So, roughly speaking, the Estonian OÜ is only useful if:
- You are in a country which doesn't have a permanent establishment problem and maybe even offers tax benefits for foreign companies (e.g. the non-dom rules of Malta, Cyprus, etc.)
- You are in a country which doesn't have a permanent establishment problem because they don't crack down on foreign company ownership (e.g. most developing countries)
In all other countries, the Estonian OÜ is likely going to cause you many tax headaches in the long run. In practice, this means:
a) Your local tax authorities don't notice or don't understand, and you're still fine, even though you'd need to file for taxes;
b) Your local tax authorities crack down on you and you need to go looking for a very expensive international tax advisor versed in Estonian and your local tax law.
Banking and being scrupulous on your personal taxes at your place of personal residence are issues, but nothing insurmountable, far from it.-
As others have said, it mostly makes sense for people outside of the EU. If you have personal residency in Spain then it is questionable whether the easier paperwork in Estonia will offset the need to do some paperwork in Spain as well.
I'm not holding my breath.
For some perspective, look at how something with a much smaller scope is being "revolutionised". I'm speaking of intra-EU dividend taxation, as regulated in EU directive 2025/50 ("FASTER"). A slightly less complicated dividend double taxation regime between EU member states. Applies to dividends on shares in public companies only. If the shares in question have not been traded within 5 days from the ex-dividend date. If the gross dividend is below 100k€. If the member state is not very small. From 2030. Using EU standardised forms. In some cases, resulting in direct reduction of the double taxation at source. In other cases, refund of excess double dividend tax within 60 days.
The clean solution would be to tax dividends in the tax residency member state of the receiving individual only. That would require a rather large leap of trust from very financialised EU member states like .ie, .lu or .nl. Perhaps possible with a long transition period and compensations. Only there's also bad faith state actors like .hu randomly torpedoing EU legislation to extract concessions. This discourages other member states from even trying to implement the clean solution.
Yes, it is fantastic and delivers on all of the promises. The only potential headache is that you must collect your e-residency card from an embassy which, depending on your location, might require travel to a nearby country.
I used Xolo but there are lots of agents in the directory. I like and recommend Xolo. No idea what the supposed issue with banking is, all of the agents have banking relationships and you can also use Revolut and Wise. My bank account was opened same day as the company.
Your details are published on the public register. The moment your registration is published you'll get lots of emails offering services, like banking (some people pretend to be Revolut but are actually just sending you affiliate links). Don't publish an email address you care about.
[1] The problem with forming a U.S. company is that all of the formation agents are layers on top of a convoluted nightmare. The formation agent can do their best to abstract away the complexity but the moment you have to peak behind the curtain you'll find yourself face to face with something very scary. The Estonian e-residency program is integrated all the way through.
I'm fairly sure the German tax authority will claim that you have a local German branch office since you live and work there.
That might be OK tax wise?
But I'd recommend starting with the tax situation in Germany.
Having limited liability through some kind of corporation can be nice.
But on the other hand, it becomes harder in Germany to pay out a varying salary as profits fluctuates throughout the year since the German tax authorities will see that as an illegal dividend payment from your company.
From this perspective it can be easier to set up some kind of sole proprietorship. Easier accounting etc and can pay out profits easier. But you get the personal liability.
This is not hard advice, just some things to point out that it gets complicated fast. So I'd recommend spending a few hundred euros on getting advice from a tax professional to begin with.
I think this is the main point and benefit of the whole thing. It can be difficult and/or expensive to set up a limited liabilty company in many countries; as an e-Stonian, it's apparently cheap and simple.
Any possible tax benefits are just a bonus.
In 2023 tried to register a business in Estonia.
I had to first get the e-residency.
This worked, (took 6 weeks I believe), but then I had to travel to another country (which had an Estonian embassy) to collect it.
Then I would have had to travel to Estonia itself to register the actual business and bank account (something like that -- it was a while ago).
(There are "done for you" business services, but from what I recall they were quite expensive, and I think would have still required the travel.)
It was theoretically doable, but due to life circumstances I wasn't able to travel at the time, so it didn't work out.
Meanwhile a few days ago, finally worked up the courage, and registered a business in the UK via a formation agent.
It took 25 minutes and $150. (Business was registered within 2 business days.) From the comfort of sitting on mine own ass, on the other side of the sea. So... yeah xD I like this way a bit better so far.
I'm using Xolo which do the accounting and local representative. 99% of my bureaucracy is uploading pdf invoices to the Xolo system. Once a year I have to spend like one hour on the anual report. That's pretty much it.
Every 5 years you have to renew your digital id. It costs a little money and if you are in the EU there will be a pickup location not far away (I had to travel internationally).
I also have to deal with my personal taxes but that's another matter.
https://denationalize.me/emigrate/goodbye-estonia-how-a-popu...
Ok, road tabbaco alcool taxes have risen in Estonia in 2025. But wtf does that matter for an e-resident?! Or that there are going to be harder ways to "secretly distribute profits". But that's just tax avoidance and they are leading with these ideas on their blog?
2% tax on profits to support the military, and 2% extra on VAT is what changed in 2025 and important for e-Residents.
It is only when he decides to withdraw the money the problem occurs.
What you're saying applies to most EU countries. Here where I live you have to reside for majority of the year in given residency to pay taxes over there.
Here's the tricky part.
Estonia is part of Schengen Area. Which means you can travel there and back without passport. There's no paper trail of your arrangements. You can easily create a reality in which you reside there for majority of time.
But again, that's not the selling part of Estonian LTD. Which is - it's extremely easygoing and as long as money stays in the company you're not paying taxes.
If you travel regularly and have an office in Estonia and you make the effective management decisions there, you are obliged to Estonian tax system only.
If you manage your company in, let's say, Germany, it is de-facto German company in the eyes of German tax authorities. When German tax authorities will find this out they will make you open UG/GmbH and pay back the corpo-tax, plus possibly a fine.
Now you will be stuck with 2 companies - Estonian and German, which is way bigger hassle. Not to mention Estonian company becomes useless/liability.
I also want to mention that practically every country has offshore-company laws like this, even places like Thailand and other SEA countries. It's not only EU.
It doesn’t make sense to me why Europeans don’t use registered agents or foreign corporation state registrations to do business as US entities in order to get up and running quickly.
Europeans complain about the difficulty starting a business can just start a business as a US entity, you’re just using the US system as the financial layer.
At the point where you’re making enough money for edge cases or moving to a more favorable jurisdiction then you can afford to because you’re in business now