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News Analysis: A Closer Look at the Luxembourg-Qatar Tax Treaty

July 2010 - Tax & Private Client. Legal Developments by Wildgen .

The Luxembourg-Qatar tax treaty, which was signed on July 3, 2009, and is generally based on the OECD model tax convention, came into force on April 9. This article will discuss the main features of the treaty. (For prior coverage, see Doc 2010-9902 or 2010 WTD 86-9; for the French text of the treaty, see Doc 2009-21556.)

Permanent Establishment: The treaty diverges from the OECD model in that a building site or construction or installation project constitutes a PE only if it lasts for more than six months. Twelve months is the norm in the OECD model. An insurance company resident in a contracting state constitutes a PE in the other contracting state if it levies premiums or covers risks on the territory of the other contracting state through a person, other than an independent agent, as a broker or general commission agent.

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News Analysis: A Closer Look at the Luxembourg-Qatar Tax Treaty