US-Luxembourg tax treaty: Update on US branch structures

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November 2016


On June 22, 2016, the United States announced an agreement with Luxembourg to amend the existing US-Luxembourg income tax treaty to change the so-called ‘triangular branch rule.’  On the same day, the Luxembourg government introduced Bill n° 7006, to retroactively apply the proposed new rule.  On October 27, 2016, the Luxembourg State Council (Conseil d'Etat) vetoed the Bill and recommended that Parliament reject the proposed new rule’s retroactive effects.

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