2022 UK-Luxembourg memorandum of understanding on arbitration under Part VI of the Multilateral Instrument

The memorandum of understanding on the arbitration process under Part VI of the Multilateral Instrument was signed on 25 July and 5 August 2022.

2022 UK-Luxembourg Double Taxation Convention and Protocol — in force

The UK-Luxembourg Double Taxation Convention and Protocol was signed on 7 June 2022 and entered into force on 22 November 2023
 
The convention is effective in the UK from:

•  1 January 2024 in respect of taxes withheld at sourcesource, to income derived on or after 1 January of the calendar year next following the year in which this Convention enters into force

•  6 April 2024 in respect of income tax and capital gains taxtax, for any year of assessment beginning on or after 6 April of the calendar year next following the year in which this Convention enters into force

•  1 April 2024 in respect of corporation taxtax, for any financial year beginning on or after 1 April of the calendar year next following the year in which this Convention enters into force

 In Luxembourg from:

•  1 January 2024 in respect of taxes withheld at sourcesource, to income derived on or after 1 January of the calendar year next following the year in which the Convention enters into force

•  1 January 2024 in respect of other taxes on incomeincome, and taxes on capital, to taxes chargeable for any taxable year beginning on or after 1 January of the calendar year next following the year in which the Convention enters into force

1967 UK-Luxembourg Double Taxation Convention as amended by the 2009 protocol — not in force

The Double Taxation Convention entered into force on 3 July 1968 and was amended by signed Protocols on:

• 18 July 1978
• 28 January 1983
• 2 July 2009

It is effective in the UK from:

• 1 April 1966 for Corporation Tax
• 6 April 1966 for Income Tax, Capital Gains Tax and surtax

It is effective in Luxembourg from 1 January 1966.

Synthesised text of the Multilateral Instrument and the 1967 UK-Luxembourg Double Taxation Convention — not in force

The 1967 UK-Luxembourg Double Taxation Convention has been modified by the Multilateral Instrument (MLI).

The modifications made by the MLI are effective in respect of the 1967 UK-Luxembourg Double Taxation Convention for both countries, for taxes withheld at source on amounts paid or credited to non-residents, from 1 January 2020.

They are effective in the UK from:

• 1 April 2020 for Corporation Tax
• 6 April 2020 for Income Tax and Capital Gains Tax

They are effective in Luxembourg for taxable periods beginning on or after 1 February 2020 for other taxes.

Pensions under the UK and Luxembourg Double Taxation Convention

Article 29 Paragraph 5 of the 2022 UK Luxembourg Double Taxation Convention contains a provision that allows individuals to choose which basis of taxation they want to apply to their pensions.

This choice is irrevocable and must be made by 23 November 2026.