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By Amar HAMOUCHE, Tax Director and Elodie SCHMIDT, Tax KM Manager, Baker McKenzie Luxembourg
The date of entry into force of the new double tax treaty ("New DTT") signed between France and Luxembourg on 20 March 2018 was uncertain until the very last minutes of 2018. France had started the ratification process back in November last year, and the Luxembourg government agreed on the implementing bill on 27 November 2018. No major amendments were expected and, therefore, a quick adoption could have been envisaged with an effective application as of 1 January 2019. However, the New DTT has not been adopted, either in France or in Luxembourg. In Luxembourg, this could easily be explained by the fact that elections were organised in October 2018 and that other...
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