TAX TALK: NEW TAX TREATY BETWEEN LUX AND FRANCE
Luxembourg and France have signed a new double taxation treaty (DTT), replacing the existing treaty that had been in force since 1958.
The accord was inked during the official state visit led by Grand Duke Henri and Grand Duchess Maria Teresa, in Paris, on 20 March 2018.
A communiqué released by Luxembourg’s finance ministry said that the new DTT has been completely revamped in comparison with its 60-year-old predecessor to include provisions that reflect the standards of the 2017 EACD Model Tax Convention, the development of which Luxembourg actively participated in, and implementing Beps minimum standards.
Among the key features of the new DTT are: the persons covered, a definition of permanent establishment, the withholding tax rate paid on dividends from real estate funds and the taxation of employment income.
In the ministry communiqué, Pierre Gramegna, the DP minister of finance, commented:
“I am delighted that the new Franco-Luxembourg tax treaty was signed during the state visit of their royal highnesses the Grand Duke and the Grand Duchess to France. This highlights the excellent bilateral relations between our two countries. The new convention is basically modernizing the current text dating from 1958 and is an innovative instrument that benefits both citizens and businesses on both sides of the border.”