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By Henri Prijot, Partner Anastasia Pakhomova, Manager, Cross-Border Tax at Deloitte
Tax treaty in 1997 and the Protocol almost 20 years later
Luxembourg has a broad tax treaty network (around 80 tax treaties in force), among others with Kazakhstan, Armenia, Moldova, Russia, Tajikistan and Uzbekistan (the so-called Commonwealth of Independent states). Besides Russia and Uzbekistan, Luxembourg concluded in 1997 a double tax treaty with another country which used to be part of the former USSR – i.e. Ukraine. The tax treaty with Ukraine concluded on 6 September 1997 and ratified in Luxembourg on 1 August 2001 remains unratified in Ukraine though, thus, making the tax treaty unenforceable.
On 30 September 2016, almost 20 years after...
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