The Luxembourg tax administration has published Circular No. 19 of 22 February 2019, which covers new rules and requirements for the determination of whether a taxpayer has a permanent establishment (PE) in a State with which Luxembourg has concluded a tax treaty. The Circular is in relation to amendments made to Luxembourg's permanent establishment rules to prevent cases where differing interpretations of the existence of a PE under a tax treaty may result in double non-taxation. The new rules include the following: If an applicable tax treaty exists, the only criteria to be used in determining whether a resident taxpayer...