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Andorra – Luxembourg: Tax Treaty Enters Into Force

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The Income and Capital Tax Treaty between Andorra and Luxembourg entered into force on 7 March 2016.

The provisions of the Treaty will take effect from 1 January 2017.

In accordance with the Treaty, the following withholding taxes will apply:

Dividends:

  • 0% if the beneficial owner holds directly and uninterruptedly, for at least a period of 12 months, at least 10% of the capital of the company paying the dividends or a participation with an acquisition cost of at least €1,200,000 in the company paying the dividends.
  • 5% if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends.
  • 15% in all other cases.

Interest: 0%.

Royalties: 0%.

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