Tuesday, 8 November 2016

US-Luxembourg tax treaty: Update on US branch structures

On June 22, 2016, the United States announced an agreement with Luxembourg to amend the existing US-Luxembourg income tax treaty to change the so-called ‘triangular branch rule.’  On the same day, the Luxembourg government introduced Bill n° 7006, to retroactively apply the proposed new rule.  On October 27, 2016, the Luxembourg State Council (Conseil d'Etat) vetoed the Bill and recommended that Parliament reject the proposed new rule’s retroactive effects.

Source & more info: PwC