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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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DT: Luxembourg: double taxation agreement, Article 13A: Alienation of offshore rights

 

Article 13A was inserted by SI84/364

Notwithstanding any other provision of this Convention, 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 and its sub-soil situated in the United Kingdom, under the authority of a licence granted by the United Kingdom, including rights to interests in or to the benefit of such oil, gas, etc., or from the alienation of shares deriving their value or the greater part of their value directly or indirectly from such rights, may be taxed in the United Kingdom.