As a reminder, a new double Tax Treaty was signed between Luxembourg and France (hereafter the “New Tax Treaty”) on March 20th 2018. For a detailed review of the various impacts, please refer to our newsletter dated March 2018.
It was long speculated that the New Tax Treaty could already enter into force as of January 1st 2019, if both countries ratified it before December 31st 2018. As the ratification process has not been completed in time, the New Tax Treaty did not yet become applicable and taxpayers thus have at least until January 1st 2020 to assess the impact of the New Tax Treaty and take the necessary steps, all while falling under the provisions of the previous tax treaty.
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