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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 19: Governmental functions

 

(1) Remuneration, including pensions, paid out of public funds of the United Kingdom or Northern Ireland or the funds of any local authority in the United Kingdom to any individual in respect of services rendered to the government of the United Kingdom or Northern Ireland or a local authority in the United Kingdom in the discharge of functions of a governmental nature shall be taxable only in the United Kingdom.

(2) Remuneration, including pensions, paid by, or out of funds created by, Luxembourg or a political subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or local authority thereof in the discharge of functions of a governmental nature shall be taxable only in-Luxembourg.

(3) The provisions of paragraphs (1) and (2) of this Article shall not apply to remuneration or pensions in respect of services rendered in connection with any trade or business. The provisions of Articles 15, 16 and 18 shall apply to such remuneration or pensions.