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Luxembourg updates Mutual Agreement Procedure

25 March 2021

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Transfer Pricing, Treaties, OECD

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Luxembourg

Executive summaryOn 11 March 2021, the Luxembourg Tax Authorities updated Circular L.G. Conv. D.I. n°60 (Circular) on the application of the mutual agreement procedure (MAP). Set forth under Article 25 of the Organisation for Economic Co-operation and Development Model Tax Convention (OECD Model Convention) and included in the various double taxation treaties (DTTs) signed by Luxembourg, the MAP aims to provide a mechanism to resolve, by means of a non-judicial procedure, cross-border tax disputes arising from the interpretation or application of a DTT provision. It should be noted that the Circular does not cover proceedings based on the Law of...