Luxembourg: Tax treaty with Spain; entities not eligible for benefits

Luxembourg entities, investment vehicles

Pursuant to a legislative change in July 2015, the standard rate of withholding tax on Spanish securities (debt securities and equities) has been reduced from the current rate of 20% to 19.5%. Shortly thereafter, the Luxembourg tax authorities in July 2015 released guidance to clarify that the following types of Luxembourg entities or investment vehicles would not benefit from application of provisions of the income tax treaty between Luxembourg and Spain.

Related content

  • Sociétés de Gestion de Patrimoine Familial (SPF) 
  • Sociétés d’Investissement à Capital Fixe (SICAF)  
  • Sociétés d’Investissement à Capital Variable (SICAV) regulated under Section II of the loi du 17 décembre 2010 concernant les organismes de placement collectif and by the loi du 13 février 2007 relative aux fonds d’investissement spécialisés—i.e., non-UCITS SICAVs.

 

Read a September 2015 report prepared by the KPMG member firm in Luxembourg: Update on Spain

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