On 22 June 2016, a draft law was submitted to the Luxembourg Parliament anticipating an upcoming amendment to the US-Luxembourg double tax treaty (DTT). Taxand Luxembourg explains the amendment.
The aim of this amendment is to stop situations of double non-taxation resulting from different interpretations of the permeant establishment (PE) concept in Luxembourg and the United States.
Example: Status quo
Discover more: Change to the tax treatment of US branch structures under US-Luxembourg tax treaty
For similar content to our Global Guide, subscribe to our mailing list and keep up to date.
Taxpayers that have implemented US branches of Luxembourg companies into their structure should already be aware of the on-going discussions regarding the US-Luxembourg DTT initiated by the US Internal Revenue Service more than a year ago.