On 14 February 2019, the Luxembourg Parliament adopted Bill of law 7333 approving the text of the Multilateral Instrument ("MLI") signed in June 2017.
The MLI is a comprehensive and flexible convention that allows signatory countries to implement a wide range of tax treaty related measures deriving from OECD base erosion and profit shifting (BEPS) project. For a detailed analysis of the choices and reservations taken by Luxembourg in this respect, see the article "Multilateral instrument: Bill of Law" published on our website.
The MLI will enter into force three months after Luxembourg deposits its instrument of ratification with the OECD. The MLI changes will apply, at the very earliest from 1 January 2020, to a specific Covered Tax Agreement (CTA) with respect to withholding taxes, and generally to all other taxes (provided, in the latter case that a company’s fiscal year coincides with the calendar year).