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Protocol to treaty between Switzerland and Luxembourg – details

09 January 2011

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Treaty Development

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Switzerland; Luxembourg

On 25 August 2009, Switzerland and Luxembourg signed an amending protocol to the Luxembourg-Switzerland income and capital tax treaty of 21 January 1993. The protocol contains an exchange of information clause in accordance with the OECD standards. The protocol further introduces an arbitration clause. For a background to this protocol. Other changes include: -   5% on dividends, if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends; -   0% on dividends derived from qualifying participations of at least 10% in a corporation...