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HMRC internal manual

Double Taxation Relief Manual

Luxembourg: Capital Gains Tax

An addition to the normal provisions of the capital gains Article (Article 13), restricting the taxation of gains from other than immovable property to the country of residence of the person making the gain, is made by Article 13A. This provides that gains derived by a resident of Luxembourg from the alienation of rights to oil, gas etc. to be produced by the exploration or exploitation of the sea bed or its subsoil in the United Kingdom may be taxed in the United Kingdom.