Luxembourg
1 Tax Treaties and Residence
1.1 How many income tax treaties are currently in force in
Luxembourg?
Luxembourg has agreed to 77 income tax treaties. Currently, 64
of these income tax treaties are in force. In total, 37 treaties
apply to Luxembourg corporate undertakings of collective investment
(SICAV/SICAF) (see also question 1.4 for South Korea).
1.2 Do they generally follow the OECD or another model?
Almost all income tax treaties entered into by Luxembourg follow
the OECD Model Convention on Income and Capital, except the income
tax treaties with Germany and France that had come into force
before the first OECD Model Convention (and despite further
renegotiations with both treaty partners). Deviations from the OECD
model treaty often relate to a few particulars, but seldom to the
entire treaty, e.g. the taxation of capital gains under the income
tax treaty with South Korea or more typically the
limitation-onbenefits provisions in certain
