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By Vanessa MOLLOY, Managing Partner and Pierre-Luc WOLFF, Counsel in the Tax Regulatory team, Harneys Luxembourg office
During the summer, the Luxembourg Parliament ratified the new Luxembourg-UK double tax treaty signed on 7 June 2022, along with a Protocol. This last Luxembourg legislative step will end many years of negotiations between the two countries and trigger the treaty’s entry into force in 2024.
The new treaty is likely to significantly impact tax structuring with the UK (especially in relation to real estate investments) as some of the new treaty provisions are materially different from the double tax treaty currently in force, which dates back to 1967.
The new treaty widens the definition of resident and...
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