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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Luxembourg: Subject to tax

The condition for exemption from Luxembourg tax in the case of interest, pensions etc in consideration of past employment and income not expressly mentioned elsewhere in the agreement (and in the case of royalties for a reduction of Luxembourg tax to 5 per cent) is that the recipient should be a resident of the United Kingdom and the beneficial owner of the income.