Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte conclude their summary of an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration
1. Persons covered
All residents in the UAE or Israel, including foreign national
individuals and companies, can benefit from the DTT. A resident in
one of the contracting states may be exempted from income tax or
obtain a credit equal to the income tax paid with respect to income
derived and taxed in the other contracting state.
2. Residents
With regard to the UAE, the DTT defines a resident as: (1) an
individual who is present in the UAE for a period, or periods,
amounting to 183 days or more in the tax year concerned and the
previous tax year; (2) a qualified government entity or corporate
Luxembourg has introduced new legislation
[1] disallowing the deduction of interest and royalties owed by Luxembourg corporate taxpayers to associated enterprises established in a jurisdiction included in Annex I of the European Union list of non-cooperative jurisdictions for tax purposes.
This new provision applies as of 1 March 2021.
Below is a summary of the main points covered by this law:
SCOPE OF THE LAW
The deduction of interest or royalties owed by Luxembourg corporate taxpayers is denied when the beneficiary of the interest or royalties meets all the following conditions:
The beneficiary of the interest or royalties is a
corporate entity according to Luxembourg Income Tax Law (opaque entities);