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.
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