Shelf Company Luxembourg

Luxembourg Double Tax Treaty Network

Individual – Foreign tax relief and tax treaties

Last updated – 08 January 2024

Foreign tax relief

Foreign income received by residents that is subject to a tax equivalent to Luxembourg income tax and is not exempted by a DTT is granted a tax credit; any non-imputable tax in excess is deductible as a tax-deductible expense.

Tax treaties

Luxembourg has signed 86 Double Tax Treaties, most of which include provisions of article 26.5 of the Organisation for Economic and Co-operation Development (OECD) model agreement on exchange of information between tax authorities.

Luxembourg is part of the European Union (EU) Regulations 1408/71 and 883/2004 (as amended) governing coordination of social security systems. In addition, Luxembourg has entered into 41 social security bilateral agreements.

Countries with which Luxembourg currently has Double Tax Treaties are as follows:

AndorraIreland (Republic of)Russia
ArmeniaIsle of ManRwanda
AustriaIsraelSan Marino
AzerbaijanItalySaudi Arabia
BotswanaKorea (Republic of)Singapore
BrazilKosovoSlovak Republic
BulgariaLaosSouth Africa
China (People’s Republic of)LiechtensteinSri Lanka
Czech RepublicMalaysiaTaiwan
FinlandMexicoTrinidad and Tobago
GreeceNetherlandsUnited Arab Emirates
GuernseyNorwayUnited Kingdom
Hong KongPanama (Republic of)United States of America

New framework agreement on social security position of cross-border teleworkers in the European Union

An EU framework agreement on the determination of the applicable social security scheme for certain cross-borders teleworkers within the European Union was published in June 2023. This framework agreement aims to introduce a more permanent arrangement to determine the social security position of cross-border teleworkers in the European Union as of 1 July 2023. More specifically, the framework agreement provides for a system (on the basis of article 16 of Regulation (EC) no. 883/2004 on the coordination of social security systems) whereby, when adopted by the member states involved, teleworking in an employee’s residence state will, if a number of conditions are met, not be taken into account for the determination of the applicable social security scheme if it accounts for less than 50% of their working time.

The principles of the framework agreement only apply when the member states involved in a given situation have both signed the agreement.