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18 Sep ’21

Double Taxation Agreement Luxembourg Germany

Until now, these profits were exempt from tax in Germany and, possibly, in Luxembourg, under the exemption from participation and under certain conditions. German real estate investment structures therefore need to be carefully examined. 3. The term `interest` used in this Article means income from government bonds, bonds or bonds, whether or not secured by a mortgage, whether or not they are entitled to participate in profits, as well as claims of any kind, as well as any other income treated as income from funds which is covered by the tax law of the State, In the event that the income is received, is loaned. Section 251. Nationals of a Contracting State may not be subject in the other State Party to any taxation or requirement which is different or more one-upmanial than the taxation and related requirements to which nationals of that other State are or may be subject in the same circumstances. 3. The competent authorities of the States Parties shall endeavour to eliminate by mutual agreement all difficulties or doubts arising in the interpretation or application of this Convention and to eliminate all difficulties which may arise from double taxation in cases not provided for in this Convention. Under the double taxation agreement between Luxembourg and Germany, capital gains from the sale of immovable property are taxed in the country where the property is located. Consequently, the capital gain which a taxpayer established in Germany derives from the sale of immovable property situated in Luxembourg is taxable in Luxembourg. BulgariaThe tax convention and international agreements of Luxembourg investment companies are defined exclusively with reference to the regulatory system; an entity is not expressly required. Nevertheless, according to the general rules on the application of double taxation treaties to sicaf and sicars partnerships organised as partnerships (e.g.

a limited liability company; SCS) are probably not considered to be entitled to contractual services. The new double taxation agreement between Germany and Luxembourg contains provisions on the taxation of collective investment schemes. Luxembourg and German companies can benefit from reduced withholding taxes on dividends and tax exemptions for the taxation of interest. On 23 April 2012, the Federal Republic of Germany and the Grand Duchy of Luxembourg signed a new Convention for the avoidance of double taxation and the prevention of fiscal evasion of income and capital (« Treaty »). The new treaty is based on the OECD Model Convention and follows the current German policy on double taxation conventions, for example. .


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