The Income and Capital Tax Treaty of 2014 between Estonia and Luxembourg activated the MFN clause of the protocol to the treaty between France and Estonia of 1997. As a result, interest paid to any kind of loan of whatever kind granted by a bank, as well as royalties, may be taxed only in the residence state of the beneficial owner. The definition of royalties has also been modified to exclude the use of or the right to use certain copyrights from the definition.
Related Posts

France: Senate approves protocol to tax treaty with Switzerland
The French upper house of Parliament (Senate) approved a new law on 3 April 2025 to ratify a protocol that will update the existing tax treaty between France and Switzerland. This protocol, which was signed on 27 June 2023, is the fifth amendment
Read More
Estonia ends tax treaty with Belarus
Estonia’s government submitted a draft law to terminate the 1997 tax treaty with Belarus on 24 March 2025. This follows after Belarus suspended key articles of the treaty, including dividends, interest, and capital gains, effective 1 June
Read More
France publishes Q1 2025 floating rate for shareholder loans
France’s Official Journal published the Q1 2025 average floating rate for bank loans with maturities over two years, set at 4.92% on 28 March 2025. This rate is used to determine the maximum deductible interest rate on loans from direct
Read More
EU approves Estonia’s special VAT measure on passenger cars
The EU has published Council Implementing Decision 2025/539 (the Decision) on 21 March 2025, which allows Estonia to continue applying a special VAT measure, deviating from parts of the VAT Directive (2006/112). Under the Decision, Estonia can
Read More
Peru advances tax treaty talks with Australia, France, Saudi Arabia, Singapore, UAE
The Peruvian Ministry of Economy and Finance announced that it is working to finalise tax treaty negotiations with Australia, France, Saudi Arabia, Singapore, and UAE on 20 March 2025. Peru has signed 10 agreements that provide a secure and
Read More
France introduces reforms to UCITS legal framework
The French government has issued Ordinance No. 2025-230 on 12 March 2025, introducing reforms to the legal framework for UCITS (Organismes de placement collectif, OPC). The measure aims to modernise and simplify regulations governing these
Read More