The Luxembourg tax administration has published the mutual agreement signed with Switzerland regarding the application of the BEPS MLI to the 1993 income and capital tax treaty between the two countries. This includes that the MLI applies for the treaty:
- with respect of taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021; and
- with respect to all other taxes levied by a Contracting State, for taxes…