Executive summary
On 11 March 2021, the Luxembourg Tax Authorities updated Circular L.G. Conv. D.I. n°60 (Circular) on the application of the mutual agreement procedure (MAP). Set forth under Article 25 of the Organisation for Economic Co-operation and Development Model Tax Convention (OECD Model Convention) and included in the various double taxation treaties (DTTs) signed by Luxembourg, the MAP aims to provide a mechanism to resolve, by means of a non-judicial procedure, cross-border tax disput…