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HMRC internal manual

International Manual

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

Limitation of relief - holding companies

There is no limitation of relief article in the convention.

But Article 30 provides that the convention as a whole shall not apply to‘holding companies entitled to any special tax benefit under the Luxembourg laws of31 July 1929, or 27 December 1937, or any similar law enacted by Luxembourg after thesignature of the convention.’

The certification box on the company claim forms requires the Luxembourg authorities tocertify that the claimant is not a holding company. But if you should seea claim or application which is not so certified, please refer toTechnical Advice Group before taking further action.