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Convention for the Avoidance of Double Taxation, Holding Luxembourg & HK

Asked in Offshore (General) for Luxembourg

Hi, i start a new thread about the convention for the avoidance of double Taxation between the Luxembourg and Hongkong.

I would like to know if this convention, can help me on my project.

I would like to make a Luxembourg company, with HK holding.
The HK company do get approx 60% of share capital about the Luxembourg company.

My question, is, at the end of year, the HK company can get the 60% of dividend, before taxation in Luxembourg ?
Exemple : 100 Euros of dividend, 60Euros go to HK company, without Luxembourg taxation.

Or Luxembourg taxation do get approx 29% of this 60Euros, before send the dividend to HK company ?

At the reverse, if i not really understand, maybe the best is Luxembourg company get 60% of Hongkong company, and Luxembourg no make taxation on the dividend received from HK company.

Thank you for your answer, and help !
Luxembourg Tax Tax
Posted by Franck on Feb 26, 2012 at 18:04


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