On 6 November 2019, Estonia has published Law in the Official Gazette, which includes measures for the implementation Council Directive (EU) 2017/1852 of 10 October 2017. The Directive includes provisions to ensure effective resolution of disputes concerning the interpretation and application of bilateral tax treaties and the Union Arbitration Convention, and in particular, disputes leading to double taxation.

The Law enters into force on 15 November 2019 and the Directive applies to complaints submitted from 1 July 2019 and onwards, relating to questions of dispute in matters of income or capital earned in a tax year commencing on or after 1 January 2018.