Canada-Estonia Tax Convention – “Most Favoured Nation” provision takes effects to eliminate source-state taxation rights in respect of certain royalties

Events have resulted in the exemption described in Article 12(7) of the Canada-Estonia Tax Convention to have effect in respect of royalties paid or credited on or after January 1, 2016.  As a result, the following types of royalties are, in the context of the circumstances described in Article 12(2), exempt from tax in the state in which they arise:

  1. copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films nor royalties in respect of works on film or videotape or other means of reproduction for use in connection with television broadcasting); or
  2. royalties for the use of, or the right to use, any patent or any information concerning industrial, commercial or scientific experience (but not including any such information provided in connection with a rental or franchise agreement).

In circumstances where tax has been withheld on the types of royalties defined above and paid after January 1, 2016:

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