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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 Multilateral Convention to implement Tax Treaty Related measures, "the MLI", signed by both Luxembourg and France in June 2017.
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