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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Luxembourg: Luxembourg holding companies

Article 30 provides that the agreement shall not apply to holding companies which are entitled to special tax benefits under certain Luxembourg laws. It follows that any such company is not a resident of Luxembourg for the purposes of the agreement, and any relief which is to be given in respect of income flowing to or from a resident of Luxembourg will not apply to income flowing to or from such a company.