DT12254 | Double Taxation Relief Manual: Luxembourg: notes

Capital Gains Tax (Article XIIIA)

An addition to the normal provisions of the capital gains Article, restricting the taxation of gains from other than immovable property to the country of residence of the person making the gain, is made by Article 13A. This provides that gains derived by a resident of Luxembourg from the alienation of rights to oil, gas etc. to be produced by the exploration or exploitation of the sea bed or its subsoil in the UK may be taxed in the UK.

Capital (Article XXIII)

Article 23 is concerned with capital or net worth taxes. The UK does not impose any such taxes at present and consequently the provisions of this Article only apply to the Luxembourg taxes, which are the capital tax and the capital element of the communal trade tax.