TSD Tax Returns: What They Are and How to Never Miss a Deadline

If you pay yourself a board member fee, distribute dividends, or employ anyone through your Estonian OÜ, you are filing TSD returns. The TSD (tulu- ja sotsiaalmaksu deklaratsioon) is Estonia's combined income tax and social tax return, filed monthly through e-MTA. It covers everything from payroll withholdings to dividend distributions to fringe benefits. Miss the deadline and penalties apply. Put a payment in the wrong part and EMTA may have questions.

This post explains what the TSD is, which parts apply to your company, what changed for payments made from October 2026, and how the cash-based timing rules work — with a worked example for a solo OÜ owner paying themselves a board member fee.

What Is the TSD?

The TSD is a monthly return that declares all income tax and social tax obligations for a given month. It is not one form — it is a main form plus several parts, each covering a different type of payment or obligation.

Filing is done electronically through e-MTA, the Estonian Tax and Customs Board's online portal. Both the filing and the corresponding tax payment are due by the 10th of the month following the payment month. If the 10th falls on a weekend or public holiday, the deadline moves to the next working day.

What Changed in October 2026

Until September 2026, payments to people were split across two annexes: Annex 1 for residents and Annex 2 for non-residents. An amendment to Ministry of Finance regulation no. 60 (RT I, 02.10.2026, 6, in force from 5 October 2026) replaced both with a single part, „Väljamaksed“ (Payments).

What is different in the new part:

• Residents and non-residents together. One part covers payments to natural persons and to non-resident legal persons.
• One row per payment, by payment date. Annex 1 had one row per person and payment type. If you pay the same person twice in a month, that is now two rows.
• Refunds and offsets are negative rows. They go in the month the refund or offset happens, linked to the original payment date. Annex 1 used a separate section with positive figures.
• Non-resident rows show the withholding rate. If the person has given you a residency certificate and a tax treaty applies, that is the treaty rate.

Which part you use depends on the month the payment was made:

The old XML upload is no longer accepted. As a transition, e-MTA accepts uploads of the current Annex 1 and Annex 2 CSV files until the end of 2027, including for periods declared on the new part. Annexes 3–8 have not changed.

The Parts of the TSD

Not every part applies to every company every month. Most small OÜ companies regularly declare payroll and occasionally dividends (Annex 7). Here is what each part covers:

Which Parts Do Most Solo OÜ Owners Use?

For a solo e-resident or founder who pays themselves a board member fee and occasionally distributes dividends:

• „Väljamaksed“ (Annex 1, or Annex 2 for non-residents, up to September 2026): every month a board fee is paid
• Annex 7 with INF 1: months when dividends are distributed
• Annex 4 or 5: occasionally — fringe benefits, or representation expenses over the limit

That's it. Annexes 3, 6, and 8 rarely apply to small companies.

Cash-Based Timing: The Most Important Rule

The TSD follows cash-based timing. The tax obligations are triggered by the payment date, not the accrual date or the period the work relates to.

This means:

• December 2025 board fees paid in January 2026 are declared on the January 2026 TSD (due 10 February 2026), using 2026 tax rates
• A September 2026 salary paid on 30 September goes on the September TSD, on Annex 1 for a resident (due 12 October 2026)
• A September 2026 salary paid on 1 October goes on the October TSD, in the „Väljamaksed“ part (due 10 November 2026)

The rate that applies is the rate in force on the day the payment is made — not when the work was done. Since October 2026, the payment date also decides which part of the TSD a payment goes in.

Why This Matters

Cash-based timing has real consequences:

1. Rate changes: If tax rates change on 1 January, anything paid in December uses the old rates, even if it's "for" January. Anything paid in January uses the new rates, even if it's "for" December.
2. Deadline management: If you pay on the last day of the month, you have until the 10th of the following month to file. If you wait one day and pay on the 1st, you get an extra month.
3. Zero months: If no payments are made in a given month, no TSD filing is required for that month — with one exception: an active, non-exempt employment relationship keeps the minimum social tax due even when no wages are paid (see Common Mistakes below).

Worked Example: Solo Board Member Fee

Here is a complete example for a solo OÜ owner paying themselves a EUR 1,500 gross board member fee in November 2026. The recipient is an Estonian resident who has requested the basic exemption be applied.

Step 1: Calculate withholdings and employer costs

Note: unemployment insurance (1.6% employee + 0.8% employer) typically does not apply to board members. If the recipient were an employee, those would be additional line items. The funded pension contribution is deducted from the income tax base before the 22% is applied — that is why the taxable income is EUR 770, not EUR 800.

Step 2: Filing timeline

All three — the filing, the social tax, and the withheld income tax — are due on the same date: the 10th of the following month.

Step 3: What appears on the TSD

The November TSD's „Väljamaksed“ part has one row for the payment. In simplified form, it records:

Had the fee been paid in September 2026 or earlier, the same figures would have gone on Annex 1. If you pay two fees to the same person on different days of the month, Annex 1 combined them into one row; the „Väljamaksed“ part has one row per payment. (The Annex 1 CSV has no payment-date column, so check how e-MTA dates the rows after an upload.)

Social tax is simply 33% of the actual fee — EUR 495.00 here. The monthly minimum social tax (EUR 292.38 in 2026, 33% of the EUR 886 minimum base) applies to active employment relationships only; a board member fee carries no top-up obligation, so no minimum check is involved.

Common Mistakes

1. Filing for the wrong month

If a November board fee is paid on 1 December, it belongs on the December TSD, not November. The payment date drives the filing period.

2. Forgetting dividend months

Dividend distributions go on Annex 7, not with payroll. If you distribute EUR 10,000 in dividends in June, the June TSD needs an Annex 7 and an INF 1 — even if your company doesn't pay any salaries or board fees that month.

3. Misapplying the minimum social tax

The monthly minimum social tax base (EUR 886 in 2026) applies to employment relationships. If you pay an employee EUR 500 gross in a month, the company pays social tax on EUR 886, not EUR 500 — that's EUR 292.38, not EUR 165 — unless an exemption qualifies (pension, student, A1 certificate, etc.). Board member fees are excluded from the minimum: social tax on a board fee is 33% of the actual amount paid, with no top-up — and zero if an A1 certificate from an EEA country or Switzerland exempts the person from Estonian social tax altogether. The flip side: a board fee below EUR 886/month does not, by itself, qualify the board member for Estonian health insurance.

4. Zero returns

If your company makes no payments at all in a given month — no board fee, no salary, no dividends — and has no employees, you do not need to file a TSD for that month. There is no obligation to file "zero returns." The carve-out is an active, non-exempt employment relationship: the minimum social tax stays due even in a month with no wages (unless the employment is suspended), so that month's TSD must still be filed and the minimum paid.

5. Not filing after paying yourself

Some new founders pay themselves a board fee but forget to file the TSD. EMTA sees the bank transfer but no corresponding declaration. This triggers automatic queries.

6. Uploading an old XML file

If your payroll software or accountant still produces the old TSD XML file, e-MTA no longer accepts it. Until the end of 2027 you can upload the Annex 1 and Annex 2 CSV files instead, or enter the payments in e-MTA by hand.

Quick Reference

For a full breakdown of all tax rates used in TSD calculations, see Estonian Tax Rates 2026. For help deciding between board member fees and salary, see Board Member vs Employee.

Auto-Generate Your TSD with Arvello

Getting the TSD right by hand means juggling four different tax calculations, remembering which part each payment belongs in, checking whether the minimum social tax base applies, and doing it all by the 10th of every month. One wrong field and you're filing a correction.

Arvello generates TSD data directly from your payroll runs and dividend distributions. When you record a board member fee or process a dividend, the system calculates all withholdings, social tax, and — for employment payments — the minimum social tax top-up if needed. Payroll comes out as CSV files in EMTA's upload format (the Annex 1 layout for residents, the Annex 2 layout for non-residents with an Estonian personal ID code), which e-MTA accepts for both the old annexes and the new „Väljamaksed“ part, so there's no re-keying numbers into a web form. A non-resident without an Estonian personal ID code or a country of residence can't go in the file; Arvello shows how many there are, and you add them in e-MTA. For dividends, Arvello prepares an INF 1 CSV file listing the recipients, which you import on form INF 1 in e-MTA. Annex 7 has no file import, so you type in the figures Arvello calculates for it.

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