The Luxembourg tax administration has published the synthesized text of the 1993 tax treaty with Romania as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized text was prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaty and the MLI take precedence and remain the legal texts applicable.

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

• in Luxembourg:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 January 2024; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 5 October 2023;
• in Romania:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 January 2024; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.

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