Changes to the UK/Luxembourg double tax treaty
On 7 June 2022, the UK and Luxembourg governments signed a protocol to amend the double tax treaty (the treaty) between both jurisdictions. As set out in our publication, the changes to the treaty are not yet in force, and the new treaty is likely to have effect from 2023 at the very earliest (although this may be at a later date as it depends on when the UK and Luxembourg governments both ratify the new treaty into law).
The new treaty contains certain significant changes, notably with respect to real estate, such that Luxembourg real estate investors holding indirect interests in UK real estate could now be subject to UK tax on capital gains, in accordance with UK domestic tax rules.
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Contacts
For more information, please contact:
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Michael Graham Legal Director London Email |
Julie Hecklen Counsel Luxembourg Email |
Cyril Poels Associate Luxembourg Email |
