DT12253 - Luxembourg: Treaty summary
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Luxembourg are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 15% | X |
| Dividends on direct investments | 5% | X |
| Conditions for lower rate on dividends on direct investments | The beneficial owner is a company the capital of which is wholly or partly divided into shares and it controls directly or indirectly at least 25% of the voting power in the company paying the dividends | X |
| Property income dividends | 15% | X |
| Interest | 0% | XI |
| Royalties | 5% | XII |
| Government pensions | Taxable only in Luxembourg | XIX |
| Pensions | Taxable only in the UK (Note 1) | XVIII |
| Arbitration | Yes | Under MLI |
Note 1: Pensions paid under the social security legislation of Luxembourg may also be taxed in Luxembourg.