On 6 April 2020, the Luxembourg law ratifying the amendment, signed on 10 October 2019 (the "Amendment"), to the new double tax treaty between France and Luxembourg and its protocol (respectively the "New Tax Treaty" and the "Protocol"), both signed on 20 March 2018 (the "Law"), has been published.
In essence, the Amendment aims at softening, as regards employment income received by French cross-border workers, the tax-credit method chosen by France to eliminate double taxation in relation to such income, in order to produce the same effects as the more usual tax-exemption method with progression.
Although the New Tax Treaty and its Protocol were signed by the Luxembourg and the French Governments more than two years ago, they have entered into force on 19 August 2019 and are applicable since the 1st January of this year only. The Amendment is also applicable with retroactive effect as from that date.
Click here to gt key provisions of the New Tax Treaty, the Protocol and the Amendment:
https://www.hoganlovells.com/en/blogs/luxembourg-blog/dtt-luxembourg-france