Luxembourg: Double Taxation Treaties applicable to SICAVs and SICAFs
On 19 September 2013, the Luxembourg Tax Authorities (LTA) updated the list of Double Taxation Treaties (DTTs) under which investment companies with fixed capital (sociétés d'investissement à capital fixe, SICAFs) and those with variable capital (sociétés d'investissement à capital variable, SICAVs) are entitled to treaty benefits based on specific agreement provided by the contracting country or on the interpretation of the text included in the DTT.
The following countries have been added:
Barbados, Macedonia, Panama, Seychelles, Tajikistan
Further information
The following lists are available on the LTA website:
- DTTs applicable to SICAVs and SICAFs;
- DTTs not applicable to SICAVs and SICAFs (no Certificate of Residence is emitted by the LTA);
- DTTs under which the eligibility to SICAVs and SICAFs is not specifically mentioned, but for which the LTA agrees to emit a Certificate of Residence (without guarantee that the eligibility will be recognised by the contracting country).
For further information, customers may contact the Clearstream Banking1 Tax Help Desk on:
| Luxembourg | Frankfurt | |
| Email: | tax@clearstream.com | tax@clearstream.com |
| Telephone: | +352-243-32835 | +49-(0) 69-2 11-1 3821 |
| Fax: | +352-243-632835 | +49-(0) 69-2 11-61 3821 |
or Clearstream Banking Customer Service or their Relationship Officer.
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1. Clearstream Banking refers collectively to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500 (CBF) and Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Register of Commerce and Companies under number B-9248 (CBL).
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