UK HMRC has published a Memorandum of Understanding (MoU) between the competent authorities of the UK and Luxembourg concerning arbitration under Article XXVII of the 1967 income and capital tax agreement between the two countries and Part VI (Arbitration) of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MoU was signed by the UK on 25 July 2022 and by Luxembourg on 5 August 2022 and is generally effective from the latter date of signature with respect to cases presented on or after 1 August 2019, as well as cases...