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By Oliver R. Hoor and Georges Bock
On 23 April 2012, the Luxembourg minister of finance Luc Frieden and the German federal minister of finance Dr. Wolfgang Schuble signed a new tax treaty in Berlin with respect to taxes on income and on capital (the new Tax Treaty). The new Tax Treaty is drafted along the lines of the OECD Model Tax Convention (OECD-MC), save for certain variations. This article provides an overview of the most important changes and the most significant variations from the OECD-MC.
1. Introduction
The existing tax treaty between Luxembourg and Germany dates back to 1958 and, quite naturally, does not have much in common with the latest versions of the OECD-MC....
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