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Dear Sir or Madam,
We are considering establishing a legal entity in Estonia that would operate in the field of medical tourism coordination, with a focus on reproductive health-related services — such as consultation, logistical support, and legal facilitation for programs involving IVF, fertility treatment, and surrogacy across the European Union.
We would like to clarify that the company will not provide any medical services directly. All medical procedures — including assisted reproductive technologies (ART) and surrogacy — will be carried out exclusively by licensed medical institutions in countries where such procedures are legally permitted (e.g., Ukraine), under separate contracts with such providers.
The role of the Estonian company would be strictly organizational and supportive, including coordination between clients and service providers, legal guidance, translation and documentation support, and logistical planning. The company would act as an intermediary or facilitator, not as a healthcare provider.
The beneficial owners of the company are Ukrainian citizens, and the target market consists of clients from across the European Union.
We kindly request your formal opinion on the following:
1. Is it legally permissible to establish and operate such a coordination and facilitation company in Estonia, given that no medical procedures will be performed on Estonian territory?
2. Are there any legal prohibitions or regulatory concerns regarding this kind of activity, particularly in relation to surrogacy-related services?
3. Would such activity require any specific license or registration under Estonian law?
4. Does the nationality of the company’s beneficial owner (Ukrainian citizen) have any impact on the ability to run this type of business in Estonia?
We seek to ensure that all aspects of our future activity will be in full compliance with Estonian legislation and relevant EU regulations. We would highly appreciate a written response or reference to the applicable legal framework.
Thank you in advance for your time and guidance. Please let us know if any additional information is required.