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Out-Law Guide | 26 Aug 2022 | 10:16 am | 64 min. read
Situated at the crossroads 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 investment – particularly in the fields of banking and finance, investment funds and holding companies. To mitigate the risks of double taxation for businesses, it has entered into comprehensive double tax treaties with over 80 jurisdictions.
The Grand Duchy treaty partners are among the most industrialised countries including all of the EU states. As with most bilateral agreements, these treaties are designed and balanced to address a specific economic context. Given their nature, tax treaties are constantly negotiated and updated to the latest international standards.
Alongside the individual tax treaties, Luxembourg has endorsed the international standard of exchange of information upon request embodied in article 26-5 of the Organisation for Economic Cooperation and Development (OECD) model tax convention. It adopted the standard on 13 March 2009.
- 7 June: new tax treaty signed with UK
- 7 June: Bill n°8023 implementing new tax treaty and protocol – signed on 13 December 2021 – with Ghana introduced in Luxembourg parliament
- 7 June: Bill n°8021 implementing new tax treaty – signed on 29 September 2021 – with Rwanda introduced in Luxembourg parliament
- 31 May: Luxembourg parliament voted to approve Bill n°7965 implementing protocol – signed on 31 August 2021 – amending tax treaty with Belgium
- 10 February: new tax treaty (including provisions of OECD Tax Convention and BEPS provisions) signed with Colombia
- 9 February: Bill n°7965 implementing protocol – signed on 31 August 2021 – amending tax treaty with Belgium introduced in Luxembourg parliament
- 13 January: new tax treaty (including provisions of OECD Tax Convention and BEPS provisions) signed with Cabo Verde
- 6 January: Bill n°7944 implementing new tax treaty – signed on 29 June 2021 – with Ethiopia introduced in Luxembourg parliament
- 22 December: Law of 17 December 2021 implementing tax treaty – signed on 11 December 2007 – and protocol – signed on 25 March 2021 – amending tax treaty with Kuwait published (Memorial A 922, 22 December 2021)
- 14 December: agreement between Luxembourg and France with regard to teleworking conditions extended until 31 March 2022 (suspension of the limit of days of teleworking for cross-border workers)
- 13 December: new tax treaty (including provisions of OECD Tax Convention and BEPS provisions) signed with Ghana
- 10 December: agreement between Luxembourg and Belgium with regard to teleworking conditions extended until 31 March 2022 (suspension of the limit of days of teleworking for cross-border workers)
- 2 December: agreement between Luxembourg and Germany with regard to teleworking conditions extended until 31 March 2022 (suspension of the limit of days of teleworking for cross-border workers)
- 29 September: new tax treaty (including provisions of OECD Tax Convention and BEPS provisions) signed with Rwanda
- 22 September: agreement between Luxembourg and Belgium with regard to teleworking conditions extended until 31 December 2021 (suspension of the limit of days of teleworking for cross-border workers)
- 13 September: agreement between Luxembourg and France with regard to teleworking conditions extended until 31 December 2021 (suspension of the limit of days of teleworking for cross-border workers)
- 6 September: agreement between Luxembourg and Germany with regard to teleworking conditions extended until 31 December 2021 (suspension of the limit of days of teleworking for cross-border workers)
- 31 August: Luxembourg and Belgium decided to extend to 34 days the number of days that cross-border workers can work from home without being subject to taxes by the Belgian authorities as of 2022
- 28 July: Bill n°7867 implementing the tax treaty – signed on 11 December 2007 – and protocol – signed on 25 March 2021 – amending tax treaty with Kuwait introduced in Luxembourg parliament
- 9 July: tax treaty with Botswana – signed on 19 September 2018 – in force as of 6 July (Memorial A 513, 9 July 2021)
- 29 June: new tax treaty (including provisions of OECD Tax Convention and BEPS provisions) signed with Ethiopia
- 15 June: agreement between Luxembourg and France with regard to teleworking conditions extended until 30 September 2021 (suspension of the limit of days of teleworking for cross-border workers)
- 11 June: agreement between Luxembourg and Belgium with regard to teleworking conditions extended until 30 September 2021 (suspension of the limit of days of teleworking for cross-border workers)
- 25 March: protocol amending the tax treaty – signed on 11 December 2007 – between Luxembourg and Kuwait, including exchange of information and OECD’s BEPS provisions, signed by both parties
- 9 March: agreement between Luxembourg and France with regard to teleworking conditions extended until 30 June 2021 (suspension of the limit of days of teleworking for cross-border workers).
- 9 March: protocol amending tax treaty with Russia – signed on 6 November 2020 – in force as of 5 March (Memorial A 178, 9 March 2021)
- 5 March: agreement between Luxembourg and Belgium with regard to teleworking conditions extended until 30 June 2021 (suspension of the limit of days of teleworking for cross-border workers)
- 26 February: law implementing protocol – signed on 6 November 2020 – amending tax treaty with Russia published (Memorial A 159, 26 February 2021)
- 25 February: protocol amending tax treaty with France – signed on 10 October 2019 – in force as of 18 February 2021 (Memorial A 151, 25 February 2021)
- 9 February: Bill n°7725 implementing protocol – signed on 6 November 2020 – amending tax treaty with Russia approved by Luxembourg parliament
- 7 December: agreement between Luxembourg and Belgium with regard to teleworking conditions extended until 31 March 2021 (suspension of the limit of days of teleworking for cross-border workers)
- 7 December: agreement between Luxembourg and France with regard to teleworking conditions extended until 31 March 2021 (suspension of the limit of days of teleworking for cross-border workers)
- 27 November: Bill n°7725 implementing protocol – signed on 6 November 2020 – amending tax treaty with Russia introduced in Luxembourg parliament
- 23 November: protocol amending tax treaty with Kazakhstan in force as of 6 November 2020 (Memorial A 925, 23 November 2020).
- 17 November: ‘amicable agreement’ signed by Luxembourg and Russia amending tax treaty for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital through the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (‘multilateral convention’)
- 9 November: ‘amicable agreement’ signed by Luxembourg and Czech Republic relating to amendments of the tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital through the multilateral convention
- 6 November: protocol signed by Luxembourg and Russia amending the tax treaty signed on 23 June 1993
- 7 October: agreement between Luxembourg and Germany with regard to teleworking conditions extended until 31 December 2020 (suspension of the limit of days of teleworking for cross-border workers).
- 25 August: Law of 14 August implementing new tax treaty – signed on 19 September 2018 – with Botswana published (Memorial A 709, 25 August 2020)
- 25 August: Law of 14 August implementing protocol – signed on 14 October 2019 – amending tax treaty with Kazakhstan published (Memorial A 708, 25 August 2020)
- 24 August: agreement between Luxembourg and France with regard to teleworking conditions extended until 31 December 2020 (suspension of the limit of days of teleworking for cross-border workers)
- 24 August: agreement between Luxembourg and Belgium with regard to teleworking conditions extended until 31 December 2020 (suspension of the limit of days of teleworking for cross-border workers)
- 22 July: Bill n°7616 implementing protocol – signed on 3 May 2012 – amending tax treaty with Kazakhstan approved by Luxembourg parliament
- 22 July: Bill n°7615 implementing new tax treaty – signed on 19 September 2018 – with Botswana approved by Luxembourg parliament
- 3 July: agreement between Luxembourg and Germany with regard to teleworking conditions extended until 31 August 2020 (suspension of the limit of days of teleworking for cross-border workers)
- 24 June: agreement between Luxembourg and France with regard to teleworking conditions extended until 31 August 2020 (suspension of the limit of days of teleworking for cross-border workers)
- 22 June: agreement between Luxembourg and Belgium with regard to teleworking conditions extended until 31 August 2020 (suspension of the limit of days of teleworking for cross-border workers)
- 10 June: Bill n°7616 implementing protocol – signed on 03 May 2012 – amending tax treaty with Kazakhstan introduced in Luxembourg parliament
- 10 June: Bill n°7615 implementing new tax treaty – signed on 19 September 2018 – with Botswana (including provisions of OECD Tax Convention) introduced in Luxembourg parliament
- 19 May: ‘amicable agreement’ signed by Luxembourg and Belgium with regard to teleworking conditions (suspension of the limit of days of teleworking for cross-border workers until 30 June 2020), in response to Covid-19 crisis
- 6 April: Law of 25 March 2020 implementing protocol amending new tax treaty with France published (Memorial A 245, 06 April 2020)
- 3 April: ‘amicable agreement’ signed by Luxembourg and Germany with regard to teleworking conditions (suspension of the limit of days of teleworking for cross-border workers), in response to Covid-19 crisis
- 19 March: protocol signed by Luxembourg and France with regard to teleworking conditions (suspension of the limit of days of teleworking for cross-border workers), in response to Covid-19 crisis
- 16 March: protocol signed by Luxembourg and Belgium with regard to teleworking conditions (suspension of the limit of days of teleworking for cross-border workers), in response to Covid-19 crisis
- 23 December: Law of 20 December 2019 implementing double tax treaty with Argentina published (Memorial A 871, 23 December 2019)
- 16 December: Bill n°7505 implementing protocol amending new tax treaty with France introduced in Luxembourg parliament
- 11 December: Bill n°7492 implementing new tax treaty – signed on 13 April 2019 – with Argentina approved by Luxembourg parliament
- 23 October: Bill n° 7492 implementing new tax treaty with Argentina (including provisions of OECD Tax Convention) introduced in Luxembourg parliament
- 10 October: protocol amending new tax treaty with France signed
- 25 September: new tax treaty with France in force as of 19 August 2019 and applicable as of 1 January 2020 (Memorial A 636, 25 September 2019)
- 16 September: protocol on exchange of information with the US in force as of 9 September 2019 and applicable as of 1 January 2020 (Memorial A 606, 16 September 2019)
- 03 September: protocol on exchange of information with Uzbekistan in force as of 26 July 2019 and applicable as of 1 January 2020 (Memorial A 583, 03 September 2019)
- 30 July: new tax treaty with Kosovo in force as of 23 July 2019 and applicable as of 1 January 2020 (Memorial A 522, 30 July 2019)
- 12 July: Law of 12 July implementing new double tax treaty with France, double tax treaty with Kosovo and two protocols to tax treaties with Belgium and Uzbekistan published (Memorial A 495, 12 July 2019)
- 02 July: Bill n°7390 approved by Luxembourg parliament. This bill implemented a new double tax treaty – signed on 20 March 2018 – with France replacing the previous treaty that was signed on 1 April 1958; implemented a double tax treaty – signed on 8 December 2017 – with Kosovo for the elimination of double taxation with respect to taxes on income and on capital and the prevention of tax evasion and avoidance (including provisions of OECD Tax Convention); and implemented two protocols to the tax treaties with Belgium (signed on 5 December 2017) and Uzbekistan (signed on 18 September 2017)
- 13 April: new tax treaty (including provisions of OECD Tax Convention, latest developments regarding ATAD and BEPS) signed with Argentina
- 14 February: new tax treaty (signed on 20 March 2018) ratified by France
- 19 September: new tax treaty (including provisions of OECD Tax Convention) signed with Botswana
- 18 July: new tax treaty with Cyprus in force as of 8 June 2018 and applicable as of 1 January 2019 (Mémorial A 597, 18 July 2018)
- 14 June: new tax treaty with Senegal in force as of 14 June 2018 and applicable as of 1 January 2019 (Mémorial A 516, 22 June 2018 )
- 20 April: Law of 17 April implementing double tax treaty with Cyprus (including provisions of OECD Tax Convention) published (Mémorial A 267, 20 April 2018). The double tax treaty will enter into force on 1 January 2019 but official publication not yet available
- 22 March: Bill n° 7226 implementing a double tax treaty – signed on 8 May 2017 – with Cyprus (including provisions of OECD Tax Convention) approved by Luxembourg parliament
- 20 March: new double tax treaty (DTT) signed by Luxembourg and France, replacing the double tax treaty that was signed on 1 April 1958. The new DTT will incorporate the latest OECD approach (reflected in the 2017 version of the OECD Model Tax Convention and in the Multilateral Convention to Implement Tax Treaty Related Measures), including: particular new rules for the taxation of cross-border payments (such as dividends, interest and royalties); important changes regarding the taxation of real estate investments made by Luxembourg companies through dedicated French investment vehicles; and redefining what constitutes a ‘permanent establishment’ for the purpose of the DTT. The DTT will enter into force once both Luxembourg and French governments complete the ratification process, and could be applicable from 1 January 2019.
- 20 December: Bill n° 7226 implementing new tax treaty with Cyprus (including provisions of OECD Tax Convention) introduced in Luxembourg parliament
- 8 December: new tax treaty (including provisions of OECD Tax Convention) signed with Kosovo
- 5 December: amending Protocol signed by Luxembourg and Belgium to existing tax treaty regarding taxation of cross-border workers, including mutual agreement concluded on 16 March 2015
- 1 December: new tax treaty (including provisions of OECD Tax Convention) signed with Cyprus in May approved by Luxembourg government
- 19 September: protocol on exchange of information on request signed with Uzbekistan. The protocol also retains the minimum standards for tax treaties resulting from the BEPS Action Plan and provides for assistance in the recovery of taxes
- 8 May: new tax treaty (including provisions of OECD Tax Convention) signed with Cyprus
- 28 April: tax treaty and protocol with Ukraine in force as of 18 April 2017 and applicable as of 1 January 2018 (Mémorial A 447 and Mémorial A 448, 28 April 2017)
- 14 March: tax treaty (signed on 6 September 1997) and protocol (signed on 30 September 2016) ratified by Ukraine
- 28 December: tax treaty with Brunei Darussalam to come into force on 26 January 2017, Uruguay on 11 January 2017 and Serbia on 27 December 2016. Applicability dates are also available (Mémorial A 307, 28 December 2016)
- 27 December: law of 23 December implementing new tax treaties with Brunei Darussalam, Senegal, Serbia, Uruguay, Ukraine (with protocol) and Hungary (replacing existing treaty) published (Mémorial A 270, 27 December 2016).
- 8 December: protocol on exchange of information with Tunisia in force as of 31 November and applicable as of 1 January 2017 (Mémorial A 247, 08 December 2016)
- 30 November: Bill n°7079 implementing new tax treaties with Brunei Darussalam, Senegal, Serbia, Uruguay, Ukraine (with protocol) and Hungary (replacing existing treaty) introduced in Luxembourg parliament
- 30 September: amending protocol signed by Luxembourg and Ukraine to the not yet in force Luxembourg-Ukraine tax treaty signed on 6 September 1997
- 7 March: new tax treaty with Andorra (including exchange of information upon request provisions) in force as of 7 March and applicable as of 1 January 2017 (Mémorial A 32 of 10 March 2016)
- 10 February: new tax treaty signed with Senegal (including provisions of OECD and UN Model Tax Conventions)
- 5 February: new tax treaty (replacing existing treaty of 23 May 2006) and new protocol on exchange of information upon request with Estonia in force as of 11 December 2015 and applicable as of 1 January 2016 (Mémorial A 12 of 5 February 2016)
- 22 January: protocol to France-Luxembourg tax treaty amending art.3 relating to the taxation of capital gain on participation in “real estate-rich” companies in force as of 1 February and applicable as of 1 January 2017 (Mémorial A 6 of 22 January 2016)
- 8 January: new tax treaty with Croatia (including exchange of information upon request provisions) in force as of 13 January and applicable as of 1 January 2017 (Mémorial A 2 of 08 January 2016).
Signed 2 June 2014
OECD model information exchange applies
Signed 13 April 2019
OECD model information exchange applies
Signed 23 June 2009
OECD model information exchange applies
Signed 18 October 1962
OECD model information exchange applies
Protocol of 21 May 1992
(effective 1 January 1995)
Protocol of 1 July 2009
(effective 1 January 2011)
Exchange of notes of 27 December 2006
(effective 1 January 2011)
Signed 6 May 2009
OECD model information exchange applies
Signed 1 December 2009
OECD model information exchange applies
Signed 17 September 1970
OECD model information exchange applies
Protocol of 11 December 2002
(effective 1 January 2005)
Protocol of 16 July 2009
(effective 1 January 2014)
Protocol of 5 December 2017
(effective 1 January 2015)
Signed 19 September 2018
OECD model information exchange applies
Signed 14 July 2015
OECD model information exchange applies
Signed 10 September 1999
OECD model information exchange applies
Protocol of 8 May 2012
(effective 1 January 2014)
Under negotiation
OCED model information exchange applies
Signed 20 June 2014
OECD model information exchange applies
Signed 8 May 2017
OECD model information exchange applies
Signed 5 March 2013
OECD model information exchange applies
Agreement of 9 November 2020
(multilateral convention)
Signed 17 November 1980
OECD model information exchange applies
Protocol of 4 June 2009
(effective 1 January 2011)
Protocol of 9 July 2013
(effective 1 January 2015)
Signed 7 July 2014
OECD model information exchange applies
Signed 1 March 1982
OECD model information exchange applies
Protocol of 24 January 1990
(effective 1 January 1990)
Protocol of 1 July 2009
(effective 1 January 2011)
Signed 1 April 1958
OECD model information exchange applies
Protocol of 8 September 1970
(effective 1 January 1971)
Protocol of 21 November 2007
(effective 1 January 2008)
Protocol of 3 June 2009
(effective 1 January 2010)
Protocol amending art. 3
relating to the taxation of capital gain
on participation in
“real estate-rich” companies
(effective 1 January 2017)
Signed 20 March 2018
OECD model information exchange applies
Protocol of 10 October 2019
(effective 18 February 2021)
Signed 23 April 2012
OECD model information exchange applies
Signed 13 December 2021
OECD model information exchange applies
Signed 10 May 2013
OECD model information exchange applies
Signed 2 November 2007
OECD model information exchange applies
Protocol of 11 November 2010
(effective 1 January 2012)
Signed 10 March 2015
OECD model information exchange applies
Signed 4 October 1999
OECD model information exchange applies
Protocol of 28 August 2009
(effective 1 January 2011)
Signed 2 June 2008
OECD model information exchange applies
Signed 14 January 1972
OECD model information exchange applies
Protocol of 27 May 2014
(effective 1 January 2016)
Signed 8 April 2013
OECD model information exchange applies
Signed 3 June 1981
OECD model information exchange applies
Protocol of 21 June 2012
(effective 1 January 2015)
Signed 5 March 1992
OECD model information exchange applies
Protocol of 25 January 2010
(effective 30 December 2011)
Signed 17 April 2013
OECD model information exchange applies
Signed 26 June 2008
OECD model information exchange applies
Protocol of 3 May 2012
(articles 5, 11 and 25 – effective 1 January 2014)
Protocol of 14 October 2019
(effective 6 November 2020)
Signed 8 December 2017
OECD model information exchange applies
Signed 11 December 2007
OECD model information exchange applies
Protocol of 25 March 2021
(effective 1 January 2022)
Signed 4 November 2012
OECD model information exchange applies
Signed 26 August 2009
OECD model information exchange applies
Signed 22 November 2004
OECD model information exchange applies
Protocol of 20 June 2014
(effective 1 January 2016)
Signed 15 May 2012
OECD model information exchange applies
Signed 29 April 1994
OECD model information exchange applies
Protocol of 30 November 2011
(effective 1 January 2014)
Signed 15 February 1995
OECD model information exchange applies
Protocol of 28 January 2014
(effective 1 January 2016)
Signed 7 February 2001
OECD model information exchange applies
Protocol of 7 October 2009
(effective 1 January 2012)
Signed 27 July 2009
OECD model information exchange applies
Signed 8 May 1968
OECD model information exchange applies
Protocol of 16 October 1990
(effective 1 January 1993)
Protocol of 29 May 2009
(effective 1 January 2011)
Signed 6 May 1983
OECD model information exchange applies
Protocol of 7 July 2009
(effective 1 January 2011)
Signed 1 October 2010
OECD model information exchange applies
Signed 14 June 1995
OECD model information exchange applies
Protocol of 7 June 2012
(effective 1 January 2014)
Signed 25 May 1999
OECD model information exchange applies
Protocol of 7 September 2010
(effective 1 January 2013)
Signed 3 July 2009
OECD model information exchange applies
Signed 14 December 1993
OECD model information exchange applies
Protocol of 4 October 2011
(effective 1 January 2014)
Signed 28 June 1993
OECD model information exchange applies
Protocol of 21 November 2011
(effective 1 January 2014)
Protocol of 6 November 2020
(effective 5 March 2021)
Signed 29 September 2021
OECD model information exchange applies
Signed 27 March 2006
OECD model information exchange applies
Protocol of 18 September 2009
(effective 1 January 2012)
Signed 7 May 2013
OECD model information exchange applies
Signed 10 February 2016
OECD model information exchange applies
Signed 15 December 2015
OECD model information exchange applies
Signed 4 June 2012
OECD model information exchange applies
Signed 9 October 2013
OECD model information exchange applies
Signed 2 April 2001
OECD model information exchange applies
Protocol of 20 June 2013
(effective 1 January 2015)
Signed 7 November 1984
OECD model information exchange applies
Protocol of 29 May 2012
(effective 1 January 2014)
Signed 3 June 1986
OECD model information exchange applies
Protocol of 10 November 2009
(effective 1 January 2011)
Signed 31 January 2013
OECD model information exchange applies
Signed 14 October 1996
OECD model information exchange applies
Protocol of 7 September 2010
(effective 1 January 2010)
Signed 21 January 1993
OECD model information exchange applies
Protocol of 25 August 2009
(effective 1 January 2011)
Protocol of 11 July 2012
(effective 1 January 2011)
Signed 19 December 2011
OECD model information exchange applies
Signed 9 June 2011
OECD model information exchange applies
Signed 27 March 1996
OECD model information exchange applies
Protocol of 8 July 2014
(effective 1 January 2017)
Signed 9 June 2003
OCED model information exchange applies
Protocol of 30 September 2009
(effective 1 January 2012)
Signed 6 September 1997
OECD model information exchange applies
Protocol of 30 September 2016
(effective 1 January 2018)
Signed 20 November 2005
OECD model information exchange applies
Protocol of 26 October 2014
(effective 1 January 2016)
Signed 24 May 1967
OECD model information exchange applies
Protocol of 24 May 1967
(effective 1 January 1966)
Protocol of 18 July 1978
(effective 6 April 1975)
Protocol of 28 January 1983
(effective 1 January 1984)
Protocol of 2 July 2009
(effective 1 January 2011)
Signed 3 April 1996
OECD model information exchange applies
Protocol of 20 May 2009
(effective 1 January 2020)
Signed 10 March 2015
OECD model information exchange applies
Signed 2 July 1997
OECD model information exchange applies
Protocol of 18 September 2017
(effective 1 January 2020)
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