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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Estonia: Royalties

Estonian tax on royalties paid to a UK resident recipient who is the beneficial owner of the royalties is reduced to

  1. 5 per cent of the gross amount where the royalties are for the use of industrial, commercial or scientific equipment,
  2. 10 per cent of the gross amount of other royalties

except where the right or property in respect of which the royalties are paid is effectively connected with a permanent establishment or fixed base which the UK resident recipient has in Estonia. In the latter circumstances, the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 14) will apply.