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. In case of ATAD CFC rule, CFC is defined as a permanent establishment or an entity if the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity. In case of CFC rule applicable to natural persons, a legal person is deemed to be controlled by Estonian residents if one or several legal or natural persons who are Estonian residents own at least 50 per cent of the shares, votes or rights to the profits of the legal person directly or together with associated persons.        The income of a foreign legal person is deemed to be the taxable income of a resident natural person if the condition prescribed above is fulfilled and the resident owns at least 10 per cent of the shares, votes or rights to the profits of the legal person directly or together with associated persons.