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By Laurent de La METTRIE, Partner and Héloïse BAILLEUX, Senior Manager, PwC Luxembourg
On March 2018, the Luxembourg and French governments signed a new double tax treaty («DTT») together with an accompanying Protocol. The new DTT seeks to modernise the existing treaty as a whole – the current treaty between Luxembourg and France was signed as far back as on 1 April 1958. The new DTT is fully «Post-BEPS». It implements the new approaches developed at international level during the OECD / G20 BEPS project, and now reflected in the 2017 version of the OECD Model Tax Convention («the 2017 OECD Model»), and in the Multi-lateral Convention to implement Tax Treaty Related measures, «the MLI», signed by both Luxembourg and France in June 2017.
As previously...
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