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By Oliver R. HOOR, Keith O’DONNELL and Samantha SCHMITZ-MERLE, Atoz *
The United States and Luxembourg are currently negotiating about the content of a protocol to the existing tax treaty concluded between both countries (the “US-Lux Tax Treaty”). The tax treatment of US permanent establishments (PEs) of Luxembourg companies is in the focus of these negotiations. In this regard, the United States and Luxembourg announced on 22 June 2016 agreement to implement a specific change to the existing US-Luxembourg tax treaty. This article outlines the current tax treatment of US PEs and analyses the planned changes to the US-Lux Tax Treaty.
1. Tax treatment of US Branches: The Status Quo
Luxembourg companies are generally subject to...
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