UK- Luxembourg Tax agreement
HMRC have published an explanatory memorandum to the protocol to the Double Taxation Convention between the UK and Luxembourg which was recently signed in London by the Financial Secretary to the Treasury and Luxembourg’s Budget Minister and entered into force on 28 April 2010.
The new protocol updates the exchange of information clauses to bring the Convention in line with the OECD’s model. The protocol is drafted to allow for the exchange of information necessary to prevent fraud.
The provisions take effect in the UK for tax years from 1 April 2011 for Corporation Tax purposes and from 6 April 2011 for Income Tax and Capital Gains Tax. In Luxembourg the provisions will take effect from 1 January 2011.