Croatia
On 24 October 2014, Croatia ratified the double tax treaty between Croatia and Luxembourg on Income and Capital signed on 20 June 2014. Luxembourg has not yet ratified the treaty.
See our Newsletter of October 2014 on the key features of this treaty.
Denmark
On 28 December 2014, the amending protocol to the Denmark - Luxembourg tax treaty on Income and Capital, signed on 9 July 2013, entered into force. The protocol has applied since 1 January 2015.
Estonia
On 8 December 2014, Estonia approved the new double tax treaty between Estonia and Luxembourg on Income and Capital, signed on 7 July 2014. Luxembourg has not yet approved the new treaty.
See our Newsletter of October 2014 on the key features of this treaty.
Guernsey
The tax treaty between Guernsey and Luxembourg on Income and Capital and its protocol entered into force on 8 August 2014 and have been effective since 1 January 2015.
For details of this new treaty, please see our Newsletter of June 2013.
Ireland
On 22 October 2014, Ireland ratified the amending protocol to the Ireland-Luxembourg double tax treaty signed on 27 May 2014. The protocol will introduce a new article 27 on exchange of information, in line with OECD standards. Luxembourg has not yet ratified the amending protocol.
Italy
On 25 October 2014, the amending protocol and exchange of letters (relating to the exchange of information), signed on 21 June 2012, to the Italy-Luxembourg tax treaty on Income and Capital entered into force. The amending protocol and exchange of letters apply from 1 January 2014.
Lithuania
On 8 December 2014, Lithuania ratified the amending protocol to the Lithuania-Luxembourg tax treaty on Income and Capital signed on 20 June 2014. Luxembourg has not yet ratified this protocol.
Mauritius
Details of the amending protocol to the Mauritius-Luxembourg tax treaty on Income and Capital, signed on 28 January 2014, have been published.
The protocol extends article 26 of the treaty on the mutual agreement procedure with an arbitration clause and provides for a new article 27 on exchange of information in line with current OECD standards.
Singapore
Details of the new Singapore-Luxembourg double tax treaty on Income and Capital have been published.
The treaty is not yet in force. Once in force and effective, this new treaty will replace the 1993 Singapore-Luxembourg tax treaty.
The new treaty is generally in line with the OECD standards.
The following withholding tax rates will apply under the treaty:
Dividends: 0% withholding tax rate on dividends.
Interest: 0% withholding rate on interest payments.
Royalties: 7% maximum withholding tax on royalties. The definition of royalties also includes films or tapes used for radio or television broadcasting.
Under this new treaty, however, certain articles deviate from the OECD model convention, in substance:
- the provision on independent services is based on the UN Model (2011);
- pensions and other payments made under a social security scheme of a contracting state will be taxable only in that state;
- the mutual agreement procedure does not contain an arbitration clause and the treaty does not include an article on assistance in the collection of taxes.
South of Africa
In November 2014, Luxembourg and South Africa installed an amending protocol to the South Africa-Luxembourg tax treaty. Details on this amending protocol have not been yet published.
United Arab Emirates
On 26 October 2014, an amending protocol to the UAE United Arab Emirates -Luxembourg tax treaty was signed. Details on this amending protocol have not been yet published.
