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By Vincent QUITTRE, Counsel, Tax at Dentons Luxembourg
The Grand Duchy of Luxembourg and the United Kingdom of Great Britain and Northern Ireland (the “UK”) signed a new treaty for the elimination of double taxation with respect to taxes on income and on capital and the prevention of tax evasion and avoidance on 7 June 2022 (the “New Treaty”). A new treaty was overdue to consider Brexit and certain BEPS (base erosion and profit shifting) actions initiated by the OECD.
The New Treaty will enter into force on 1 January 2024 for Luxembourg and UK withholding taxes as well as for all other Luxembourg taxes(1) and will replace the previous treaty in force between the two jurisdictions (the “Preceding Treaty”)(2).
One of the key...
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