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Luxembourg Publishes Synthesized Texts of Tax Treaties with Malaysia and Russia as Impacted by the BEPS MLI — Orbitax Tax News & Alerts

The Luxembourg tax administration has published the synthesized texts of the tax treaties with Malaysia and Russia as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 2002 Luxembourg-Malaysia tax treaty:

  • with respect of taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 December 2021.

The MLI applies for the 1993 Luxembourg-Russia tax treaty:

  • with respect of taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes in Luxembourg, for taxes levied with respect to taxable periods beginning on or after 30 November 2020; and
  • with respect to all other taxes in Russia, for taxes levied with respect to taxable periods beginning on or after 1 January 2021.

Click the following link for the tax treaty page of the Luxembourg tax administration, which includes the MLI synthesized texts.