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The new Luxembourg/UK double tax treaty

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures. 

On 7 June 2022 the UK and Luxembourg signed a new double tax treaty and protocol. The 1967 treaty it will replace is one of the older treaties and retains provisions that are important to certain Luxembourg holding company structures. However the new treaty reflects recent post-BEPS models of balancing taxing rights between states. When combined with other developments such as the proposed Unshell EU Directive (ATAD 3) and a new qualifying asset holding company (QAHC) regime in the UK the new treaty will likely be a significant factor for re-evaluating old structures.

Withholding taxes

UK holding companies are no longer able to access the Parent Subsidiary Directive or Interest and Royalties Directive. It is therefore interesting to see the position agreed in respect of withholding taxes in the...

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