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

Luxembourg - Treatment of “family holdings” (SPF) clarified with Japan 

July 26:  The governments of Luxembourg and Japan on 19 July 2013 exchanged notes concerning the Luxembourg-Japan income tax treaty (1992) and amending Protocol (2010) with respect to taxation of income of “family holdings” (SPFs).

Under the July 2013 notes, SPFs cannot benefit from the reduced withholding tax rates or tax exemptions under the income tax treaty agreements. Rather, reduced withholding tax rates or exemptions based on domestic law will continue to apply.

While the treaty tax rate provisions do not extend to family holdings, this does not preclude an exchange of information with respect to the SPF investment vehicles.

The amending exchange of notes will enter into force and be effective 18 August 2013.

Read a July 2013 report prepared by the KPMG member firm in Luxembourg: Luxembourg and Japan clarify the treatment of Family Holdings (SPF)

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