Situated at the crossroad of Europe, the Grand-Duchy of Luxembourg is based on a dynamic and open economy which actively promotes the development of cross border trade and investments. Its major role in matter of international trade in the sectors of banking and finance, investment funds and holding companies has for a consequence that a strong network of double tax treaties has been developed over the years. To that end, Luxembourg has entered into more than 70 comprehensive double tax treaties based on the OECD model tax convention on income and capital in order to mitigate the risks of double taxation for businesses.
The Grand Duchy treaty partners are amongst the most industrialised countries with inter alia all of the states in the European Union but Cyprus, the United States, Japan, Brazil, China, Mexico, Hong Kong and Russia, Canada. Luxembourg tax treaties as most bilateral agreements are designed and balanced to address a specific economic context. Given their very nature, tax treaties are constantly negotiated and updated to the latest international standards.
Another perspective to the steady expansion of Luxembourg tax treaties must be added. Luxembourg endorsed on 13 March 2009 the international standard of exchange of information upon request embodied in article 26-5 of the OECD model tax convention.
LATEST UPDATES:
- 30 September 2016. Luxembourg and Ukraine signed an amending Protocol to the not yet in force Luxembourg-Ukraine tax treaty signed on 6 September 1997.
- 07 March 2016. New tax treaty with Andorra (including exchange of information upon request provisions) is in in force as of 07 March 2016 and will be applicable as of 01 January 2017 (Mémorial A 32 of 10 March 2016).
- 10 February 2016. New tax treaty was signed with Senegal (including provisions of OECD and UN Models Tax Conventions).
- 05 February 2016. New tax treaty (replacing the existing treaty of 23 May 2006) and new protocol on exchange of information upon request with Estonia are in force as of 11 December 2015 and are applicable as of 01 January 2016 (Mémorial A 12 of 5 February 2016).
- 22 January 2016. Protocol to France-Luxembourg tax treaty amending art. 3 relating to the taxation of capital gain on participation in “real estate-rich” companies will be in force as of 01 February 2016 and will be applicable as of 01 January 2017 (Mémorial A 6 of 22 January 2016). For more information please refer to our alert: Fourth amendment of the Luxembourg and France double tax treaty.
- 08 January 2016. New tax treaty with Croatia (including exchange of information upon request provisions) will be in in force as of 13 January 2016 and will be applicable as of 01 January 2017 (Mémorial A 2 of 08 January 2016).
2015
- 31 December 2015. New tax treaty (replacing the existing treaty of 6 March 1993) and new protocol on exchange of information upon request with Singapore are in force as of 28 December 2015 and will be applicable as of 01 January 2016 (Mémorial A 263 of 31 December 2015).
- 24 December 2015. Protocols on exchange of information upon request with Ireland, Mauritius, Lithuania and United Arab Emirates are in force as of 11 December 2015 and will be applicable as of 01 January 2016 (Mémorial A 247 of 24 December 2015).
- 15 December 2015. New tax treaty was signed with Serbia.
- 11 December 2015. Law of 07 December 2015 implementing new tax treaties with Andorra, Croatia, Estonia and Singapore and protocols to existing tax treaties with United Arab Emirates, France, Ireland, Lithuania, Mauritius and Tunisia was published in the Official Journal (Mémorial A 232, 11 December 2015). Entry into force dates will be precised in forthcoming publications.
- 18 November 2015. Luxembourg adopted draft law 6826 implementing new tax treaties with Andorra, Croatia, Estonia and Singapore and protocols to existing tax treaties with United Arab Emirates, France, Ireland, Lithuania, Mauritius and Tunisia. Protocol to the France-Luxembourg tax treaty has to be ratified by France. For more information please refer to our alert: Fourth amendment of the Luxembourg and France double tax treaty.
- 12 October 2015. Luxembourg and Ecuador Ministers of Finance agreed to consider the advisability to conclude a tax treaty.
- 07 October 2015. Luxembourg and Bolivian Ministers of Finance agreed to consider the advisability to conclude a tax treaty.
- 14 July 2015. New tax treaty was signed with Brunei and will include exchange of information upon request provisions.
- 18 March 2015. In its 2014 Annual report, the Luxembourg Direct Tax Authorities reported that 727 exchange of information upon request, spontaneous information exchange and automatic exchange of information have been handled by the Luxembourg Direct Tax Authorities in 2014 (10,5% more than in 2013).
- 10 March 2015. New tax treaty was signed with Uruguay.
- 10 March 2015. New tax treaty was signed with Hungary. The new treaty will replace the Hungary-Luxembourg income and capital tax Treaty of 1990 and will include exchange of information upon request provisions.
