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HMRC internal manual

Double Taxation Relief Manual

DT: Luxembourg: double taxation agreement, Article 2: Taxes covered

Article 2(1) was substituted by SI80/567 as below;

(1) The taxes which are the subject of this Convention are:

(a) In the United Kingdom of Great Britain and Northern Ireland:

(i) the income tax; (ii) the corporation tax; (iii) the petroleum revenue tax; (iv) the development land tax; and (v) the capital gains tax (hereinafter referred to as `United Kingdom tax`).

(b) In Luxembourg:

(i) the income tax on individuals (l’impot sur le revenu des personnes physiques);

(ii) the tax on fees of directors of companies (l’impot sur les tantiemes);

(iii) the corporation tax (l’impot sur le revenu des collectivites);

(iv) the capital tax (l’impot sur la fortune); and

(v) the communal trade tax, including tax on the total amount of wages and salaries (l’impot commercial communal, y compris l’impot sur le total des salaires)

(hereinafter referred to as `Luxembourg tax`).

(2) The Convention shall also apply to any identical or substantially similar taxeswhich are subsequently imposed in addition to, or in place of, the existing taxes.