Article
New Protocol To The Income Tax Treaty Between Luxembourg And Poland
Besides introducing an OECD-compliant full exchange of tax information procedure (still excluding "fishing expeditions"), the major changes to the Treaty concern the introduction of an anti-abuse/limitation on benefits provision which is new ground in Luxembourg tax treaty policy and the possibility for the situs state to tax the sale of shares in a "land-rich" entity (provided however that domestic tax law permits such taxation, which, depending on the structuring scenario, does not necessarily
ELVINGER HOSS PRUSSEN, société anonyme
