On 18 January 2017, UK HMRC published an update concerning withholding tax on royalties under the 1994 income and capital tax treaty with Estonia. The update confirms that due to the MFN clause included in the exchange of notes to the 1994 Estonia-UK treaty relating to Article 12 (Royalties) and the entry into force of the 2014 protocol to the 2002 Estonia-Switzerland tax treaty on 16 October 2015, the exemption for royalties provided under the protocol also applies under the Estonia-UK treat…