DT12253 - Luxembourg: Treaty summary

The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the 바카라 사이트˜treaty rate바카라 사이트™ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The 바카라 사이트˜treaty rate바카라 사이트™ is the maximum rate at which the UK and Luxembourg are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject Comments Article
Portfolio dividends 15% X
Dividends on direct investments 5% X
Conditions for lower rate on dividends on direct investments The beneficial owner is a company the capital of which is wholly or partly divided into shares and it controls directly or indirectly at least 25% of the voting power in the company paying the dividends X
Property income dividends 15% X
Interest 0% XI
Royalties 5% XII
바카라 사이트 pensions Taxable only in Luxembourg XIX
Pensions Taxable only in the UK (Note 1) XVIII
Arbitration Yes Under MLI

Note 1: Pensions paid under the social security legislation of Luxembourg may also be taxed in Luxembourg.