Global

Details

  • Service: Tax, International Executive Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 7/26/2013

Luxembourg - Protocol amending treaty with Russia is ratified 

July 26: A Protocol amending the Luxembourg-Russia income tax treaty has been ratified and thus will be effective beginning 1 January 2014.

The Protocol was signed in 2011, and was ratified by Russia in late December 2012 and by Luxembourg on 4 July 2013.


Among the changes to the treaty contained in the Protocol are measures that:


  • Reduce the withholding tax rate on dividends (reduced from 10% to 5% in certain circumstances)
  • Revise the rules for taxation of income from immovable property
  • Provide “other income” is subject to taxation in its state of origin
  • Allow for an exchange of tax information
  • Introduce anti-treaty shopping rules under a limitation of benefits provision
  • Provide guidance on determining the tax residence of legal entities
  • Extend the definition of a permanent establishment (PE)

The Protocol reflects a general trend in international tax of enhanced tax transparency and reinforcement of substance of group companies.


Read a July 2013 report [PDF 124 KB] prepared by the KPMG member firm in Luxembourg: Luxembourg and Russia ratify treaty protocol




©2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

 

Share this

Share this

Subscribe

Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)


Already a Subscriber? Login


Not a member? Subscribe now