Details have become available of the amending protocol to the Luxembourg-Russia income and capital tax treaty of 28 June 1993, signed on 21 November 2011. The protocol was signed in the French and Russian languages, all texts being equally authentic. The most important amendments are the following: -   Art. II of the protocol provides for the addition of a new Art. 4(4) (Resident) and provides for a mutual agreement procedure if the place of effective management of a company cannot be determined. For the determination, the following facts are particularly relevant:       -   the place where...