On 14 February 2019, the Luxembourg Parliament adopted Bill of law 7333 approving the text of the
Multilateral Instrument ("MLI") signed
in June 2017.
The MLI is a comprehensive and flexible convention that allows
signatory countries to implement a wide range of tax treaty related
measures deriving from OECD base erosion and profit shifting (BEPS)
project. For a detailed analysis of the choices and reservations
taken by Luxembourg in this respect, see the article "
Multilateral instrument: Bill of Law" published on our
website.
The MLI will enter into force three months after Luxembourg
deposits its instrument of ratification with the OECD. The MLI
changes will apply, at the very earliest from 1 January 2020, to a
specific Covered Tax Agreement (CTA) with respect to withholding
taxes, and generally to all other taxes (provided, in the latter
case that a company's fiscal year coincides with the calendar
year).
