SolvedDT12253 | Double Taxation Relief Manual: Luxembourg: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Luxembourg are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 0% | X |
| Dividends on direct investments | 0% | X |
| Conditions for lower rate on dividends on direct investments | Beneficial owner is a resident of the other Contracting State (no ownership or voting power requirement) | X |
| Property income dividends | 15% | X |
| Interest | 0% | XI |
| Royalties | 0% | XII |
| Government pensions | Taxable only in Luxembourg unless the individual is a resident and national on the UK. (Note 1) | XIX |
| Pensions | Taxable in both countries with the exception of pensions arising from contributions made under a complementary pension scheme which are taxable only in Luxembourg. (Note 1) | XVIII |
| Arbitration | Yes | Under MLI |
Note 1: An election can be made in some circumstances to benefit from the previsions of the previous agreement.