Insights

Fresh thinking and actionable insights that address critical issues your organization faces.

Learn more

Resources

Services

KPMG's multi-disciplinary approach and deep, practical industry knowledge help clients meet challenges and respond to opportunities.

Services to meet your business goals

Technology Alliances

KPMG has market-leading alliances with many of the world's leading software and services vendors.

View all Alliances

Industries

Helping clients meet their business challenges begins with an in-depth understanding of the industries in which they work. That’s why KPMG LLP established its industry-driven structure. In fact, KPMG LLP was the first of the Big Four firms to organize itself along the same industry lines as clients.

How We Work

We bring together passionate problem-solvers, innovative technologies, and full-service capabilities to create opportunity with every insight.

Learn more

Careers & Culture

What is culture? Culture is how we do things around here. It is the combination of a predominant mindset, actions (both big and small) that we all commit to every day, and the underlying processes, programs and systems supporting how work gets done.

Learn more
Relevant Results
Sorry, there are no results matching your search.
Autocomplete suggestions are available. Use up and down arrows to review and enter to select.
See more results

Luxembourg: Implications of protocol to tax treaty with Germany

The protocol came into force 1 January 2024.

May 14, 2024

Luxembourg and Germany signed an amending protocol to the Luxembourg-Germany income tax treaty on 6 July 2023, which incorporated certain provisions implementing the BEPS Multilateral Instrument (MLI) and modified several other significant provisions. The protocol came into force 1 January 2024.

The key changes introduced by the protocol include:

  • Extension of the tolerance threshold for cross-border workers to 34 days 
  • Introduction of a new “effectively taxed” clause to avoid double non-taxation
  • Amendment of the provisions related to treaty benefits granted to investment funds 
  • Revision of the provisions on exit tax in the case of a change of tax residence
  • Insertion of the anti-abuse provision of the MLI (preamble and principal purpose test)

The Luxembourg tax authorities also recently released guidance (Circular L.G.- Conv. D.I. n°71 dated 18 March 2024) regarding the protocol.

Read a May 2024 report prepared by the KPMG member firm in Luxembourg discussing implications of the protocol for individuals and cross-border workers

Read a May 2024 report prepared by the KPMG member firm in Luxembourg discussing implications of the protocol for corporate taxpayers and investment funds

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.

KPMG. Make the Difference.


Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

© 2025 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance.

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.

By submitting, you agree that KPMG LLP may process any personal information you provide pursuant to KPMG LLP's Privacy Statement.

An error occurred. Please contact customer support.

Job seekers

Visit our careers section or search our jobs database.

Search now!

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Submit

Office locations

View locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Learn more

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Contact

Headline