26/08/15

Tax Treaties News

Austria

On 18 June 2015, Austria and Luxembourg signed an amending exchange of notes regarding adjustments concerning the new exchange of information procedures under the double tax treaty concluded between Austria and Luxembourg on Income and Capital, as amended. Details on the notes have not yet been published.

France

On 1 July 2015, the French Government approved the amending protocol signed on 5 September 2014 to the double tax treaty between France and Luxembourg on Income and Capital of 1958, as amended (the “Protocol”). The Protocol was submitted to the French National Assembly for ratification.

The Protocol adds a new paragraph to Article 3 of the tax treaty relating to the disposal of shares in companies holding mainly real estate. Please refer to our October 2014 Newsletter on the Protocol for further details.

In Luxembourg, the bill ratifying the Protocol was submitted to Parliament on 9 June 2015.

Hungary

On 23 June 2015, Hungary ratified the new double tax treaty between Hungary and Luxembourg on Income and Capital signed on 10 March 2015. However, Luxembourg has not yet ratified the treaty. Once in force and effective, the new treaty will replace the current double tax treaty of 1990. Details on this new tax treaty have not been published yet but will be highlighted in a later edition, once available.

Brunei

On 14 July 2015, the double tax treaty between Brunei and Luxembourg on Income and Capital, initialled on 13 December 2012 was signed by the two States in Brussels.

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