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26 November 2014
The Luxembourg Double Tax Treaties Network

Latest updates:

- 26 November 2014. Protocol on exchange of information with Italy is in force as of 25 October 2014 and will be applicable as of 01 January 2015 (Mémorial A 212, 25 November 2014).

- 26 October 2014. Protocol on exchange of information upon request was signed with United Arab Emirates.

- 10 October 2014. New tax treaty with Isle of Man is in force as of 05 August 2014 and will be applicable as of 01 January 2015 (Mémorial A 190, 10 October 2014).

- 07 October 2014. New tax treaty with Jersey is in force as of 05 August 2014 and new tax treaty with Guersney as of 08 August 2014. Both will be applicable as of 01 January 2015 (Mémorial A 186 of 07 October 2014 and corrigendum Mémorial A 190, 10 October 2014).

- 25 September 2014. Protocol on exchange of information upon request with Slovenia is in force as of 22 August 2014 and will be applicable as of 01 January 2015 (Mémorial A 183, 25 September 2014). 

- 16 September 2014. New tax treaty with Saudi Arabia is in force as of 01 September 2014 (Mémorial A 179, 16 September 2014). This treaty will be applicable as of 01 January 2015.

- 05 September 2014. The French and Luxembourg Finance Ministers signed, on 5 September 2014, a Protocol amending Article 3 (the “Protocol”) of the France-Luxembourg double tax treaty for the avoidance of double taxation and the establishment of rules of reciprocal administrative assistance with respect to taxes on income and fortune (the “Tax Treaty”). For more information, please refer to the article "Fourth amendment of the Luxembourg and France double tax treaty".

- 01 September 2014. New tax treaty with Taïwan is in force as of 25 July 2014 (Mémorial A 172, 01 September 2014). This treaty will be applicable as of 01 January 2015. The Law of 12 July 2014 implementing this tax treaty was published in the Official Journal on 15 July 2014 (Mémorial A 123).

- 14 August 2014. New tax treaty with Czech Republic is in force as of  31 July 2014 (Mémorial A 162, 14 August 2014). This treaty will be applicable as of 01 January 2015. The tax treaty signed on 18 March 1991 shall cease to be in force and in effect on the date of the entry into effect of this new tax treaty.

- 18 July 2014. Law of 01 July 2014 implementing new tax treaties with Saudi Arabia, Guernsey, Isle of Man, Jersey, Czech Republic and protocols to existing tax treaties with Denmark and Slovenia was published in the Official Journal (Mémorial A 126, 18 July 2014). Entry into force dates will be precised in forthcoming publications.

- 08 July 2014. Protocol on exchange of information upon request was signed with Tunisia.

- 07 July 2014. New tax treaty with Estonia was signed.

- 20 June 2014. New tax treaty was signed with Croatia and protocol on exchange of information upon request was signed with Lithuania.

- 03 June 2014. New tax treaty with Andorra was signed.

- 27 May 2014. Protocol on exchange of information upon request was signed with Ireland.

- 11 April 2014. New tax treaty with Sri Lanka is in force as of 11 April 2014 (Mémorial A 59, 11 April 2014). This treaty will be applicable as of 01 January 2015.

- 12 March 2014. In its 2013 Annual Report, the Luxembourg Direct Tax Authorities reported that they have negotiated new tax treaties with Hungary, New Zealand, United Kingdom and Uruguay. It is also reported that 659 exchange of information upon request, spontaneous information exchange and automatic exchange of information have been handled by the Luxembourg Direct Tax Authorities in 2013 (11,5% more than in 2012).

- 07 March 2014. New tax treaty with Laos (Lao People's Democratic Republic) is in force as of 21 March 2014 (Mémorial A 30, 07 March 2014). This treaty will be applicable as of 01 January 2015.

- 31 January 2014. Pierre Gramegna, Luxembourg Minister of Finance, signed a protocol with Jagdish Dharamchand Koonjul, ambassador of the Mauritius Republic .This protocol will include the international standard of exchange of information upon request and amend several provisions.

- 23 December 2013. Protocol on exchange of information upon request with Canada is in force as of 10 December 2013 and new treaty with Kazakhstan (protocol on exchange of information upon request included) is in force as of 11 December 2013 (Mémorial A 221, 23 December 2013). Both will be applicable as of 01 January 2014.

- 09 October 2013. Luc Frieden, Luxembourg Minister of Finance, signed the new tax treaty with Tharman Shanmugaratnam, Singapore Minister of Finance.

- 09  October 2013. New tax treaty with Germany is in force as of 30 September 2013 (replacing the original dating back 1958) and protocol on exchange of information upon request with South Korea is in force as of 04 Septembre 2013 (Mémorial A 179, 09 October 2013). Both will be applicable as of 01 January 2014.

- 13 September 2013. Protocol on exchange of information upon request with Poland is in force as of 25 July 2013 and with Russia as of 30 July 2013. New tax treaty with Macedonia is in force as 23 July 2013, with Tajikistan as of 27 July 2013 and with Seychelles as of 19 August 2013 (Mémorial A 168, 13 September 2013). The three new tax treaties include the international standard of exchange of information upon request.

- 30 July 2013. Luxembourg and Mongolia to begin new tax treaty negotiations to facilitate better access to investment services.

- 26 July 2013. Protocol on exchange of information upon request with Belgium is in force as of 25 June 2013 and with Switzerland as of 11 July 2013 (Mémorial A 134, 26 July 2013).

- 25 July 2013. Protocols on exchange of information upon request with Romania and Malta are in force as of 11 July 2013 (Mémorial A 132, 25 July 2013).

- 04 July 2013. Law of 14 June 2013 implementing new tax treaties with Germany, Kazakhstan (protocol included), Laos (Lao People's Democratic Republic), Macedonia, Seychelles, Sri Lanka and Tajikistan and protocols to existing tax treaties with Canada, South Korea, Italy, Malta, Poland, Romania, Russia and Switzerland was published in the Official Journal (Mémorial A 144, 04 July 2013). Entry into force dates will be precised in forthcoming publications.

- 28 February 2013. In its 2012 Annual Report issued on 25 February, the Luxembourg Direct Tax Authorities reported that they have negotiated new tax treaties with Botswana, Brunei, Chili, Czech Republic, Guernsey, Jersey and Isle of Man and protocol with Estonia. It is also reported that 592 exchange of information upon request, spontaneous information exchange and automatic exchange of information have been handled by the Luxembourg Direct Tax Authorities in 2012.

Update - List of double tax treaties in force and in negotiation

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 matter 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 70 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.

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