The Double Taxation Relief and International Tax Enforcement (Luxembourg) Order, SI 2022/1055, brings into effect arrangements set out in the 2022 Convention and Protocol agreed between the UK and Luxembourg for the avoidance of double taxation and prevention of evasion. The 2022 text is set out in the Schedule to the Order.
The 2022 agreement largely updates existing provisions to bring them in line with the OECD Model tax convention on income and capital, and includes the BEPS minimum standards. It also deals with the allocation of taxing rights for various purposes. The explanatory memorandum to the Order provides a useful breakdown of the 2022 provisions, on an article-by-article basis.
The Double Taxation Relief and International Tax Enforcement (Luxembourg) Order, SI 2022/1055, brings into effect arrangements set out in the 2022 Convention and Protocol agreed between the UK and Luxembourg for the avoidance of double taxation and prevention of evasion. The 2022 text is set out in the Schedule to the Order.
The 2022 agreement largely updates existing provisions to bring them in line with the OECD Model tax convention on income and capital, and includes the BEPS minimum standards. It also deals with the allocation of taxing rights for various purposes. The explanatory memorandum to the Order provides a useful breakdown of the 2022 provisions, on an article-by-article basis.
