The protocol aligns the agreement with OECD and BEPS standards.
Moldova’s State Tax Service announced that the amending protocol to the 2007 income and capital tax treaty with Luxembourg has entered into force on 14 July 2025.
The protocol aligns the agreement with OECD and BEPS standards, particularly A revised preamble reflecting BEPS principles; an update to Article 24 allowing taxpayers to initiate a mutual agreement procedure with the competent authority of either contracting state; replacement of Article 25 with OECD-compliant rules on information exchange; and introduction of a new anti-abuse rule in Article 26A (Entitlement to Benefits), denying treaty benefits where one of the main purposes of a transaction was to obtain them, unless such benefits align with the treaty’s purpose.
Earlier, Luxembourg released the Law of 25 March 2025 in the Official Gazette on 7 April 2025, which facilitated the ratification of the protocol.
The protocol was signed on 25 June 2024.
