As of January 1, 2019, there are two CFC rules in Estonia:  1) CFC rule from the ATAD Directive applicable to companies; 2) CFC rule applicable to natural persons. ATAD CFC rule is not applicable to an entity or permanent establishment with accounting profits of no more than EUR 750 000, and non-trading income of no more than EUR 75 000. In case of CFC rule applicable to natural persons, CFC's income is taxed in Estonia if CFC is located in a low tax rate territory. A low tax rate territory is a foreign state or a territory with an independent tax jurisdiction in a foreign state, which does not impose a tax on the profits earned or distributed by a legal person or where such tax is less than one-third of the income tax which a natural person who is an Estonian resident would have to pay on a similar amount of business income. There is a white list of the jurisdictions that are not considered to be a low tax rate territory. This list includes all Estonian tax treaty partners.