03/12/20

The Luxembourg Double Tax Treaties Network

List of double tax treaties in force and in negotiation as of 23 November 2020.

Situated at the crossroad of Europe, the Grand-Duchy of Luxembourg is based on a dynamic and open economy which actively promotes the development of cross border trade and investments. Its major role in terms of international trade in the sectors of banking and finance, investment funds and holding companies has for a consequence that a strong network of double tax treaties has been developed over the years. To that end, Luxembourg has entered into more than 80 comprehensive double tax treaties based on the OECD model tax convention on income and capital in order to mitigate the risks of double taxation for businesses.

The Grand Duchy treaty partners are amongst the most industrialised countries with inter alia all of the states in the European Union but Cyprus, the United States, Japan, Brazil, China, Mexico, Hong Kong and Russia, Canada. Luxembourg tax treaties as most bilateral agreements are designed and balanced to address a specific economic context. Given their very nature, tax treaties are constantly negotiated and updated to the latest international standards.

Another perspective to the steady expansion of Luxembourg tax treaties must be added. Luxembourg endorsed on 13 March 2009 the international standard of exchange of information upon request embodied in article 26-5 of the OECD model tax convention.

Latest updates:

2020

- 23 November 2020. Protocol amending the Tax treaty with Kazakhstan is in force as of 6 November 2020 (Memorial A 925, 23 November 2020).

- 17 November 2020. Luxembourg and Russia signed an Amicable Agreement amending the Tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital  through the Multilateral Convention to implement Tax treaty related measures to prevent base erosion and profit shifting.

- 9 November 2020. Luxembourg and the Czech Republic signed an Amicable Agreement relating to the amendments of the Tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital through the Multilateral Convention to implement Tax treaty related measures to prevent base erosion and profit shifting.

- 6 November 2020. Luxembourg and Russia signed a Protocol amending the Tax treaty signed on 23 June 1993.

- 07 October 2020. Agreement between Luxembourg and Germany with regard to teleworking conditions has been extended until 31 December 2020 (suspension of the limit of days of teleworking for cross-border workers).

- 25 August 2020. Law of 14 August implementing new Tax treaty - signed on 19 September 2018 - with Botswana has been published (Memorial A 709, 25 August 2020).

- 25 August 2020. Law of 14 August implementing the Protocol - signed on 14 October 2019 - amending the Tax treaty with Kazakhstan has been published (Memorial A 708, 25 August 2020).

- 24 August 2020. Agreement between Luxembourg and France with regard to teleworking conditions has been extended until 31 December 2020 (suspension of the limit of days of teleworking for cross-border workers).

- 24 August 2020. Agreement between Luxembourg and Belgium with regard to teleworking conditions has been extended until 31 December 2020 (suspension of the limit of days of teleworking for cross-border workers).

- 22 July 2020. Luxembourg Parliament voted to approve Bill n°7616 implementing the Protocol - signed on 03 May 2012 - amending the Tax treaty with Kazakhstan.

- 22 July 2020. Luxembourg Parliament voted to approve Bill n°7615 implementing new Tax treaty - signed on 19 September 2018 - with Botswana.

- 03 July 2020. Agreement between Luxembourg and Germany with regard to teleworking conditions has been extended until 31 August 2020 (suspension of the limit of days of teleworking for cross-border workers).

- 24 June 2020. Agreement between Luxembourg and France with regard to teleworking conditions has been extended until 31 August 2020 (suspension of the limit of days of teleworking for cross-border workers).

- 22 June 2020. Agreement between Luxembourg and Belgium with regard to teleworking conditions has been extended until 31 August 2020 (suspension of the limit of days of teleworking for cross-border workers).

- 10 June 2020. Bill n°7616 implementing the Protocol – signed on 03 May 2012 - amending the Tax treaty with Kazakhstan was introduced in Luxembourg Parliament.

- 10 June 2020. Bill n°7615 implementing new Tax treaty – signed on 19 September 2018 - with Botswana (including provisions of OECD Tax Convention) was introduced in Luxembourg Parliament.

- 19 May 2020. Further to the exceptional COVID-19 crisis, Luxembourg and Belgium signed an amicable Agreement with regard to teleworking conditions (suspension of the limit of days of teleworking for cross-border workers until 30 June 2020).

- 06 April 2020. Law of 25 March 2020 implementing the Protocol amending the new Tax treaty with France has been published (Memorial A 245, 06 April 2020).

- 03 April 2020. Further to the exceptional COVID-19 crisis, Luxembourg and Germany signed an amicable Agreement with regard to teleworking conditions (suspension of the limit of days of teleworking for cross-border workers).

- 19 March 2020. Further to the exceptional COVID-19 crisis, Luxembourg and France signed a Protocol with regard to teleworking conditions (suspension of the limit of days of teleworking for cross-border workers).

- 16 March 2020. Further to the exceptional COVID-19 crisis, Luxembourg and Belgium signed a Protocol with regard to teleworking conditions (suspension of the limit of days of teleworking for cross-border workers).

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