LexGo

Luxembourg ratifies new France-Luxembourg double tax treaty
02/07/2019

Today, the draft law ratifying the double tax treaty ("DTT") signed with France on 20 March 2018 was passed by the Luxembourg Parliament (first parliamentary reading). A dispensation from a second parliamentary reading is expected to be granted by the State Council in the coming days or weeks so that the draft law can become law immediately and the instruments of ratification be subsequently exchanged with France.

Since the ratification procedure has already been finalised in France and is about to be finalised in Luxembourg, the DTT will take effect as follows:

  • in respect to taxes withheld at source, the new provisions will apply to income derived on or after 1 January 2020; and
     
  • in respect to other taxes on income and taxes on capital, the new provisions will apply to taxes chargeable for any tax year beginning on or after 1 January 2020.

The aim of the new DTT is to replace the existing treaty that was signed in 1958 and amended 4 times in subsequent years. The DTT follows the structure and, for the most part, the content of the 2017 OECD Model Tax Convention. To get an overview of the main provisions of the DTT, which will, in particular, give rise to important changes regarding the taxation of real estate investments made by Luxembourg companies through dedicated French investment vehicles, please read our 16 November 2018 tax alert: https://www.atoz.lu/media/luxembourg-and-france-launch-ratification-procedure-their-new-tax-treaty

Now that timing for the application of the new provisions has become clear, Luxembourg taxpayers with investments in France or that plan to invest in France should seek advice from their tax adviser in order to analyse the potential impact of the new provisions on their investments and take action if necessary.

Related : Atoz Luxembourg ( Mr. Romain Tiffon ,  Mrs. Samantha Schmitz )

[+ http://www.atoz.lu]

Mr. Romain Tiffon Mr. Romain Tiffon
Head of International and Corporate Tax
romain.tiffon@atoz.lu
Mrs. Samantha Schmitz Mrs. Samantha Schmitz
Chief Knowledge Officer
samantha.schmitz@atoz.lu

Click here to see the ad(s)
All articles Corporate tax

Lastest articles Corporate tax

The draft Budget Law for the year 2021 is released!
19/10/2020

On 14 October 2020, Luxembourg's Minister of Finance, Pierre Gramegna, tabled before the Parliament the draft budget l...

The draft Budget Law for the year 2021 is released! Read more

Budget 2021: various tax measures to address the impact of the COVID-19 pandemic and support a su...
16/10/2020

ON 14 OCTOBER 2020, THE LUXEMBOURG GOVERNMENT FILED BUDGET BILL 7666 WITH THE LUXEMBOURG PARLIAMENT

Read more

2021 Budget – Tax measures
15/10/2020

On 14 October 2020, the 2021 budget draft law was presented to Parliament. The Government decided that the time was not ri...

Read more

OECD releases updated Pillar Two proposal for global minimum effective taxation
14/10/2020

On 12 October 2020, the OECD released for public consultation updated reports on its two-pillar proposal to address the ta...

OECD releases updated Pillar Two proposal for global minimum effective taxation Read more

Lastest articles by Mr. Romain Tiffon

COVID-19: Luxembourg extends DAC6, CRS and FATCA reporting deadlines
07/07/2020

Yesterday, the draft law implementing the optional deadline extensions of EU Directive of 24 June 2020 (the “Directi...

Read more

DAC6 and CRS deadline extensions – Update
05/06/2020

Yesterday, the Luxembourg Finance Ministry reported that EU Member States have agreed on a compromise proposal for a Direc...

Read more

DAC6 and CRS deadlines extended
13/05/2020

On 8 May 2020, the European Commission released a directive proposal amending the EU Directive on Administrative Cooperati...

Read more

COVID-19 crisis: New draft law to extend deadlines in fiscal matters
08/04/2020

On 8 April 2020, Luxembourg Parliament released the draft law n°7555 addressing the extension of deadlines i...

Read more

Lastest articles by Mrs. Samantha Schmitz

2021 Budget – Tax measures
15/10/2020

On 14 October 2020, the 2021 budget draft law was presented to Parliament. The Government decided that the time was not ri...

Read more

COVID-19: Luxembourg extends DAC6, CRS and FATCA reporting deadlines
07/07/2020

Yesterday, the draft law implementing the optional deadline extensions of EU Directive of 24 June 2020 (the “Directi...

Read more

DAC6 and CRS deadline extensions – Update
05/06/2020

Yesterday, the Luxembourg Finance Ministry reported that EU Member States have agreed on a compromise proposal for a Direc...

Read more

European Commission requests Luxembourg to amend its tax rules on foreign securitisation enterpri...
18/05/2020

Yesterday (15 May), the European Commission sent 2 letters of formal notice to Luxembourg relating to securitisation, one ...

Read more

LexGO Network