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Luxembourg publishes draft legislation approving protocol amending tax treaty with Germany, improving taxation of funds

03 November 2023

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Treaties

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Germany, Luxembourg

The Luxembourg Minister of Foreign and European Affairs recently submitted to the Parliament a draft ratification law (Draft Law) approving a protocol that amends the existing double tax treaty (DTT) with Germany.The most relevant amendments include:Undertakings for Collective Investment that meet the definition are now considered resident and are entitled to treaty withholding tax rates.Simplifications are included for cross-border employees working outside the country of their employer (including in home office).Executive summaryOn 6 July 2023, the Luxembourg and German Ministers of Finance signed an amending protocol (the Amending Protocol) to the existing DTT dated 23 April 2012 and the related...