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 applies only in case of CFC’s income arising from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company's income.  In case of CFC rule applicable to natural persons, there is an exemption for a CFC if more than 50 per cent of its annual income is derived from actual economic activity or if the state or territory of location of the legal person provides the Estonian tax authority with information concerning the income of a person controlled by Estonian residents.