• Luxembourg - Germany
    New Tax Treaty Enters Into Force


    The new Income and Capital Tax Treaty between Luxembourg and Germany entered into force on 30 September 2013. The new treaty replaces the old Luxembourg - Germany tax treaty of 1958.

    The provisions of the new treaty will have effect from 1 January 2014.

    In accordance with the new treaty, the following withholding taxes will apply:

    • Dividends:
      • 5% if the beneficial owner is a company (other than a partnership or an investment company) which holds directly at least 10% of the capital of the company paying the dividends.
      • 15% if the dividend paying company is a real estate investment company whose profits are fully or partially exempt from tax, or that may deduct the dividends in calculating its profits.
      • 15% in all other cases.

    • Interest: 0%.

    • Royalties: 5%.
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