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By Miriam Keusen, Director International Tax, KPMG Luxembourg
Snapshot of the current diverging views applied in practice
Where a Luxembourg company distributes a dividend to a German pool of assets (Sondervermö-gen)(1), it might be wondering whether it should apply a withholding tax of 0%, 5% or 15%. At this stage the response is not clear: The different tax offices apply diverging views. Given German investment funds regularly use Luxembourg as a platform for outbound investments, the issue is not a one-off but of interest to numerous investment managers.
The new non-double tax treaty concluded between Luxembourg and Germany (“the Treaty”), which entered into force on 1 January 2014, gives rise to diverging views due to the...
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