New Double Tax Agreement between Cyprus and Luxembourg

The new double  tax agreement between Cyprus and Luxembourg was recently published on the Luxembourg tax administration's website.  The agreement – the first such agreement to be signed by the two countries – closely follows the latest  Organisation for Economic Cooperation and Development (OECD) Model Tax Convention for the Avoidance of Double Taxation on Income and on Capital.  In line with the OECD Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting, it also includes:
•  a preamble clarifying that  it is not designed to create  opportunities for double  non-taxation or reduced taxation through evasion  or avoidance; and
•  a principal purpose test-based general anti-avoidance rule