HMRC has confirmed that, with effect from 16 October 2015, no withholding tax on royalties is permitted under the UK/Estonia treaty, by virtue of the ‘most favoured nation’ provision. The provision was triggered by Estonia entering into a double taxation agreement with Switzerland, which provides for taxation of royalties in the resident state only. The UK is therefore entitled to the same treatment.
HMRC has confirmed that, with effect from 16 October 2015, no withholding tax on royalties is permitted under the UK/Estonia treaty, by virtue of the ‘most favoured nation’ provision. The provision was triggered by Estonia entering into a double taxation agreement with Switzerland, which provides for taxation of royalties in the resident state only. The UK is therefore entitled to the same treatment.
