Japan and Estonia signed an agreement on avoidance of double taxation

Japan and Estonia signed the Agreement on Avoidance of Double Taxation in International Trade and Investment (hereinafter referred to as the "SAP") on August 30, which was signed on March 16, 2017. The SIPC contains mutual obligations of the parties in the implementation of export-import transactions and investments.
In accordance with SOI, the dividend tax rate is 10%, which is paid in the state of origin of the capital. At the same time, the 0% rate will apply to payers who simultaneously meet the conditions: (1) own at least 10% of the company's shares (2) within 6 months. The tax rate for royalties is 5%, which is paid in the state of origin of capital.
The agreement between Japan and Estonia comes into force after 30 days from the date of signing and falls on September 29, 2017.

A source: http://www.mof.go.jp/tax_policy/summary/international/press_release/20170830ee_b.pdf