On 24 December 2024, the Luxembourg Direct Tax Authorities issued the new circular L.G.-A No. 61 replacing the previous circular dated 8 December 2017 (please see our previous newsletter dated 8 February 2008 for more details) which outlines the procedure for applying for tax residency certificates for collective investment funds (the “Circular”).
The main change compared with the previous version of the Circular concerns the scope of double tax treaties covered by the Circular. Such scope has indeed been extended to include amended double tax treaties and those which have been newly entered into by Luxembourg (i.e. the double tax treaties with Botswana, Cyprus, Ethiopia, France, Hungary, Kosovo, United Kingdom, and Rwanda). All of these new double tax treaties include a positive provision treating investment funds incorporated under the form of companies as “residents” within the meaning of the double tax treaty.
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