A new double tax treaty has been signed between Luxembourg and the UK. Once it comes into effect, a beneficial new lower rate of dividend withholding will be available and treaty benefits will be extended to certain fund structures; however, certain real estate holding structures relying on protections in the old treaty will become taxable in the UK without grandfathering. Luxembourg structures should be reviewed in light of this and other international developments, especially as there may now be suitable alternatives.
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A new double tax treaty has been signed between Luxembourg and the UK. Once it comes into effect, a beneficial new lower rate of dividend withholding will be available and treaty benefits will be extended to certain fund structures; however, certain real estate holding structures relying on protections in the old treaty will become taxable in the UK without grandfathering. Luxembourg structures should be reviewed in light of this and other international developments, especially as there may now be suitable alternatives.
If you are not a subscriber, subscribe now to read this content.
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