As of the 22nd of September 2021, this list enumerates and briefly defines all existing double tax treaties signed by Luxembourg and those under further negotiations.

Network on Luxembourg Double tax treaties

Strategically located at the crossroads of Europe, Luxembourg enjoys a highly dynamic and open economy that inspires the creation of cross border trade and investments. Its emerging leader role in international trade for banking, finance, investment funds, and holding companies has opened doors to the establishment of a strong network of double tax treaties with a long list of EU and non-EU member nations.

To date, Luxembourg has successfully entered more than 80 comprehensive double tax treaties by following the OECD model tax convention on income and capital, which allows for mitigating risks of double taxation for businesses set up in Luxembourg.

The most common treaty partners of Luxembourg are some of the most industrialized countries with inter alia of states included in the European Union.

Strategic Luxembourg tax treaties

Like most bilateral agreements, Luxembourg tax treaties are well-strategized and balanced to address a specific economic context or industry. Given its nature, tax treaties are continuously being negotiated and updated to meet the latest international standards.

Yet another clear perspective to the continuous expansion of Luxembourg tax treaties must be emphasized more than ever. In the 13th of March 2008, the Grand Duchy of Luxembourg endorsed an international standards for exchange of information upon request as stated in article 26-5 of the OECD model tax convention.

 Latest Updates

2021

• 22 September 2021

Agreement between Luxembourg and Belgium in relation to teleworking conditions has been successfully extended until 31 December 2021. This suspends in the limitation of days for teleworking cross-border workers.

• 13 September 2021 

Agreement between Luxembourg and France in relation to teleworking conditions has been successfully extended until 31 December 2021. This suspends in the limitation of days for teleworking cross-border workers

• 6 September 2021

 Agreement between Luxembourg and Germany in relation to teleworking conditions has been successfully extended until 31 December 2021. This suspends in the limitation of days for teleworking cross-border workers

• 31 August 2021

 An agreement between Luxembourg and Belgium that defined 34 days as the number of days cross-border workers can work from home without being subject to taxes imposed by Belgian Authorities

• 28 July 2021

Also known as Bill no. 7867 that implements the tax treaty signed on 11 December 2007 and the related Protocol signed on 25 March 2021, which clearly states amending the tax treaty with Kuwait  as first introduced in the Luxembourg Parliament

• 9 July 2021

The tax treaty between Luxembourg and Botswana signed on 19 September 2018 will be enforced as of 6 July 2021

• 29 June 2021

 A brand-new tax treaty signed with Ethiopia that includes provisions of OECD Tax Conventions and BEPS provisions

• 15 June 2021

 Agreement between Luxembourg and France regarding teleworking conditions extended until 30 September 2021. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 11 June 2021

Agreement between Luxembourg and Belgium regarding teleworking conditions extended until 30 September 2021. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 25 May 2021

Protocol amending the tax treaty signed on 11 December 2007 between Luxembourg and Kuwait, which includes information exchange and OECD’s BEPS provisions 

• 09 March 2021

Agreement between Luxembourg and France regarding teleworking conditions extended until 30 June 2021. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 09 March 2021

Protocol amending the tax treaty signed on 6 November 2020 between Luxembourg and Russia is to be enforced as of 5 March 2021 (Memorial A178)

• 5 March 2021

Agreement between Luxembourg and France Belgium teleworking conditions extended until 30 June 2021. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 26 February 2021

 Law implementing the protocol signed on 6 November 2021, which includes the publishing of amended tax treaty between Luxembourg and Russia (Memorial A159, 26 February 2021)

• 25 February 2021

Protocol amending the tax treaty signed on 6 November 2020 between Luxembourg and France is to be enforced as of 18 February 2021 (Memorial A 151)

• 9 February 2021

The Luxembourg Parliament voted to approve Bill no. 7725 implementing the amended tax treaty with Russia signed on 6 November 2020

 2020

• 7 December 2020

Agreement between Luxembourg and Belgium teleworking conditions extended until 31 March 2021. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 7 December 2020

Agreement between Luxembourg and France teleworking conditions extended until 31 March 2021. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 27 November 2020

 Bill no. 7725 states the implementation of the protocol signed on 6 November 2020 which includes amending the tax treaty with Russia as introduced by the Luxembourg Parliament

• 23 November 2020

Protocol amending the tax treaty signed on 6 November 2020 between Luxembourg and Kazakhstan is to be enforced as of 6 November 2020 (Memorial A 925)

• 17 November 2020

Signed amicable agreement between Luxembourg and Russia to amend the tax treaty to avoid double taxation and prevent fiscal evasion in relation with capital and income taxes through the Multilateral Convention to implement tax treaty stating measures to prevent base erosion and profit shifting

• 9 November 2020

Signed amicable agreement between Luxembourg and Czech Republic to amend the tax treaty to avoid double taxation and prevent fiscal evasion in relation with capital and income taxes through the Multilateral Convention to implement tax treaty stating measures to prevent base erosion and profit shifting

• 6 November 2020

 Signed protocol amending tax treaty between Luxembourg and Russia signed on 23 June 1993

• 7 October 2020

Agreement between Luxembourg and Germany teleworking conditions extended until 31 December 2020. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 25 August 2020

Law on new tax treary signed  on 19 September 2018 between Luxembourg and Botswana has been published (Memorial A 709)

• 25 August 2020

Law implementing the protocol signed on 6 November 2021, which includes the publishing of amended tax treaty between Luxembourg and Kazakhstan (Memorial A 1708)

• 24 August 2020

Agreement between Luxembourg and France teleworking conditions extended until 31 December 2020. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 24 August 2020

Agreement between Luxembourg and Belgium teleworking conditions extended until 31 December 2020. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 22 July 2020

Voted approval of Bill no. 7617  by the Luxembourg Parliament to implement the protocol signed on 03 Mary 2012, thereby amending the treaty with Kazakhstan

• 22 July 2020

Voted approval of Bill no. 7615  by the Luxembourg Parliament to implement the protocol signed on 19 September 2018, thereby amending the treaty with Botswana

• 03 July 2020

Agreement between Luxembourg and Germany teleworking conditions extended until 31 August 2020. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 24 June 2020

Agreement between Luxembourg and France teleworking conditions extended until 31 August 2020. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 22 June 2020

Agreement between Luxembourg and Belgium teleworking conditions extended until 31 August 2020. It clearly states the suspension to the limit of number of days of teleworking for cross-border workers

• 10 June 2020

Voted approval of Bill no. 7615  by the Luxembourg Parliament to implement the protocol signed on 03 May 2012, thereby amending the treaty with Kazakhstan

• 10 June 2020

Voted approval of Bill no. 7615  by the Luxembourg Parliament to implement the protocol signed on 19 September 2018, thereby amending the treaty with Botswana as per provisions of OECD Tax Convention

• 19 May 2020

 Due to the prevailing COVID-19 crisis, Luxembourg and Belgium signed an amicable agreement regarding teleworking condition, indicating suspension of the limit of days of teleworking for cross border workers until 30 June 2020

• 06 April 2020

Law on new tax treaty signed  on 19 September 2018 between Luxembourg and France has been published (Memorial A 245)

• 03 April 2020

Due to the prevailing COVID-19 crisis, Luxembourg and Germany signed an amicable agreement regarding teleworking condition, indicating suspension of the limit of days of teleworking for cross border workers

•  19 March 2020

Due to the prevailing COVID-19 crisis, Luxembourg and France signed an amicable agreement regarding teleworking condition, indicating suspension of the limit of days of teleworking for cross border workers

• 15 March 2020

Due to the prevailing COVID-19 crisis, Luxembourg and Belgium signed an amicable agreement regarding teleworking condition, indicating suspension of the limit of days of teleworking for cross border workers

 2019

• 23 December 2019

Law of December 2019 that directs the implementation of a double tax treaty between Luxembourg and Argentina was published . (Memorial A 871)

• 16 December 2019

Implementation of Bill no. 7605  by the Luxembourg Parliament amending the treaty with France

• 11 December 2019

Voted approval of Bill no. 7492  by the Luxembourg Parliament to implement the protocol signed on 03 May 2012, thereby amending the treaty with Argentina

• 23 October 2019

Voted approval of Bill no. 7492  by the Luxembourg Parliament that included OECD Tax Convention provisions signed on 03 May 2012, thereby amending the treaty with Argentina

• 10 October 2019

New protocol amendment on the new tax treaty with France was signed

• 25 September 2020

New tax treaty with France was enforced as of 19 August 2019 and applicable since 01 January 2020 (Memorial A 636)

• 16 September 2019

Protocol on information exchange between Luxembourg and the United States of America was enforced as of 09 September 2019 and will be applicable starting 01 January 2020 (Memorial A 606)

• 03 September 2019

Protocol on information exchange between Luxembourg and the Uzbekistan was enforced as of 26 July 2019 and will be applicable starting 01 January 2020 (Memorial A 583)

• 30 July 2019

New tax treaty with Kosovo was enforced as of 19 August 2019 and applicable since 01 January 2020 (Memorial A 522)

• 12 July 2019

New laws implemented for double tax treaties with France and Kosovo, protocols on tax treaties Belgium, and Uzbekistan (Memorial A 495)

• 02 July 2019

 Luxembourg Parliament approved Bill no. 7390 that includes the following:

1. Implementation of a new double tax treaty with France signed on 20 March 2018 to replace the previous treaty signed on 1 April 1958
2. Implementation of a new double tax treaty with Kosovo signed on 8 December 2017 to eliminate double taxation in relation to income and capital taxes, as well as the prevention of tax evasion and avoidance. It also includes provisions of OECD Tax Convention
3. Implementation of two protocols under the tax treaties with Belgium and Uzbekistan signed on 5 December 2017 and 18 September 2018 respectively

• 13 April 2019

New tax treaty with Argentina that includes provisions of OECD Tax Convention and new developments associated with ATAD and BEPS

• 14 February 2019

New tax treaty between Luxembourg and France was ratified and signed on 20 March 2018

2018

• 19 September 2018

New tax treaty between Luxembourg and Botswana including provisions of OECD Tax Convention

• 18 July 2018

New tax treaty between Luxembourg and Cyprus was enforced since 08 June 2018 and applicable from 01 January 2019 (Memorial A 597)

• 14 June 2018

New tax treaty between Luxembourg and Senegal was enforced since 14 June 2018 and applicable from 01 January 2019 (Memorial A 516)

• 20 April 2018

Law of 17 April that directs the implementation of a double tax treaty between Luxembourg and Cyprus, which includes provisions of OECD Tax Convention was published (Memorial A 267.) This double tax treaty shall be enforced on 01 January but official publication still unavailable

• 22 March 2018

Voted approval of Bill no. 7226  by the Luxembourg Parliament that included OECD Tax Convention provisions signed on 08 May 2017, thereby amending the treaty with Cyprus

• 20 March 2018

A new double tax treaty between Luxembourg and France was signed to replace the double tax treaty signed on 1 April 1958. It includes the latest OECD Multilateral Conventions to Implement Tax Related measures. The new double tax treaty features new taxation rules concerning cross-border payments such as dividends, interest, royalties, as well as other critical changes in relation to real estate tax investments made by Luxembourg companies via French investment vehicles, which in turn redefines what constitutes a permanent establishment for DTT purposes. The double tax treaty will be enforced once Luxembourg and France accomplish the ratification process. All provisions will be applicable starting 01 January 2019

 2017

• 20 December 2017

Voted approval of Bill no. 7226  by the Luxembourg Parliament that included OECD Tax Convention provisions signed on 08 May 2017, thereby amending the treaty with Cyprus

• 08 December 2017

New tax treaty that includes OECD Tax Convention provisions signed between Luxembourg and Kosovo

• 05 December12017

Amendment on the protocol existing to existing tax treaty regarding the taxation of cross-border workers between Luxembourg and Belgium was concluded on 16 March 2015

• 01 December 2017

A new tax treaty was approved by the Luxembourg Parliament on a new tax treaty included provisions on OECD Tax Convention with Cyprus

• 19 September 2017

Signed protocol on information exchange upon request signed between Luxembourg and Uzbekistan. The protocols state the minimum standards for tax treaties leading as a result of the BEPS Action Plan providing assistance in recovering taxes

• 08 May 2018

A new tax treaty including provisions of OECD Tax Convention was signed between Luxembourg and Cyprus

• 28 April 2018

A tax treaty between Luxembourg and Ukraine were enforced on 18 April 107 and will be applicable starting 01 January 2018 ( Memorial A 447 and A 448)

• 14 March 2018

The ratification of the tax treaty signed 01 September 1997 and the protocol signed on 30 September 2016 was signed with Ukraine

 2016

• 28 December 2016

A tax treaty with Brunei Darussalam will be enforced starting 26 January 2017, with Uruguay starting 11 January 2017, and Serbia starting 27 December 2017. Applicability dates are now available ( Memorial A 307)

• 27 December 2016

Law of 23 December 2017 which states the implantation of new tax treaty with Brunei Darussalam, Senegal, Serbia, Uruguay, and Ukraine, including protocols, as well as replacing the existing treaty with Hungary was published (Memorial A 270)

• 08 December 2016

Signed protocol on information exchange signed between Luxembourg and Tunisia was enforced on 31 November 2016 and deemed applicable starting 01 January 2017 (Memorial A 247)

• 20 November 2016

The Luxembourg Parliament approved Bill no. 7079 that starts the implementation of new tax treaties with Brunei Darussalam, Senegal, Serbia, Uruguay, and Ukraine with protocols, as well as replacing the existing tax treaty

• 30 September 2016

An amending protocol was signed between Luxembourg and Ukraine in relation to the Luxembourg-Ukraine tax treaty signed on 6 September 1997

• 07 March 2016

Signed new tax treaty between Luxembourg and Andorra that includes information exchange upon provisions were enforced starting 07 March 2016 and will be deemed applicable starting 01 January 2017 (Memorial A 32)

• 10 February 2016

A new tax treaty was signed between Luxembourg and Senegal which includes provisions of the OECD Tax Convention

• 05 February 2016

A new treaty that replaces the existing treaty of 23 May 2006 and a new protocol on information exchange upon request was made between Luxembourg and Estonia and was enforced on 11 December 2016 and deemed applicable starting 01 January 2017 (Memorial A 6)

• 08 January 2016

A new tax treaty between Luxembourg and Croatia  which includes provisions on information exchange upon request was enforced on 13 January 2016 and deemed applicable starting 01 January 2017 (Memorial A 2)

Luxembourg is an attractive country for investment due to its double tax treaties with EU and non-EU Member States. To benefit from double tax treaty agreements when your business intends to deal with Luxembourg, please contact your Damalion experts.