Great Fund Insights: The new Luxembourg/United Kingdom tax treaty has finally been signed!
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Patrick Mischo
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Naomi Lawton
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Sophie Balliet
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Franz Kerger
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Guilhèm Becvort
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Johanna Tschurtschenthaler
Counsel
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Zofia White
Senior Associate
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Samara Hiscock
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Stephanie Yiolitou
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More than four yeas after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail.
As expected, the new tax treaty is broadly in line with the most recent OECD Model Tax Convention and notably includes a "property-rich clause" as well as a principal purpose test provision. It also narrows the circumstances in which withholding will be required from payments of dividends and interest and (through the Protocol) provides additional details on the types of investment vehicles that will be regarded as residents.
The treaty must be ratified by each country before it can come into force and is expected to have effect in 2023.
For the full text of the treaty please, click here.