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Luxembourg aims to eliminate withholding tax on dividends
International Tax Review, October 1, 2008
Luxembourg's budget for 2009,
introduced into parliament on October 1, will reduce the corporate income
tax rate and abolish withholding tax on dividends paid to recipients in
countries that have a tax treaty with the country.
Luxembourg's budget for 2009, introduced into parliament on October 1,
will reduce the corporate income tax rate and abolish withholding tax on
dividends paid to recipients in countries that have a tax treaty with the
country.
These proposals are among a list of measures designed to further enhance
Luxembourg as a preferred jurisdiction for investment.
At the moment the participation exemption is limited to distributions
made to Luxembourg permanent establishments of corporations resident in tax
treaty countries. For all other companies, Luxembourg's treaties generally
provide for a reduced rate of withholding. The proposed change would enhance
the attractiveness of Luxembourg and its participation exemption regime,
most notably in the context of the repatriation of profits.
"The draft bill is very positive for the international business
community," said Georges Deitz, a tax partner at Deloitte in Luxembourg,
"even more so in these difficult economic times."
Luxembourg tax professionals lobbied the government for some time to
eliminate withholding tax on dividends. "We didn't expect it to go through
this year though," Deitz said. "It's a nice surprise."
This move, together with the abolition of capital duty which was
announced two months ago, is a very positive one for the country, Deitz
added. "These are two very important changes and two very important signs
that Luxembourg is doing something to attract multinational firms even in
difficult budget times," he said.
The prime minister announced earlier this year that the corporate income
tax rate will be gradually reduced from 29.63% to 25.5%.
Parliament is expected to approve the draft reform in the next couple of
weeks.
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