Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.
On 7 June 2022 the UK and Luxembourg signed a new double tax treaty and protocol. The 1967 treaty it will replace is one of the older treaties and retains provisions that are important to certain Luxembourg holding company structures. However the new treaty reflects recent post-BEPS models of balancing taxing rights between states. When combined with other developments such as the proposed Unshell EU Directive (ATAD 3) and a new qualifying asset holding company (QAHC) regime in the UK the new treaty will likely be a significant factor for re-evaluating old structures.
Withholding taxes
UK holding companies are no longer able to access the Parent Subsidiary Directive or Interest and Royalties Directive. It is therefore interesting to see the position agreed in respect of withholding taxes in the...
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Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.
On 7 June 2022 the UK and Luxembourg signed a new double tax treaty and protocol. The 1967 treaty it will replace is one of the older treaties and retains provisions that are important to certain Luxembourg holding company structures. However the new treaty reflects recent post-BEPS models of balancing taxing rights between states. When combined with other developments such as the proposed Unshell EU Directive (ATAD 3) and a new qualifying asset holding company (QAHC) regime in the UK the new treaty will likely be a significant factor for re-evaluating old structures.
Withholding taxes
UK holding companies are no longer able to access the Parent Subsidiary Directive or Interest and Royalties Directive. It is therefore interesting to see the position agreed in respect of withholding taxes in the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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