Le Luxembourg conclut à son tour un traité avec Hong Kong
Auteur | Thierry Afschrift |
Fonction | Licencié en droit, avec grande distinction de l'Université Libre de Bruxelles |
Nous avions dÈj‡ soulignÈ, dans IDEFISC, que la Belgique avait conclu un traitÈ prÈventif de la double imposition, particuliËrement intÈressant, avec Hong Kong. Celui-ci permet notamment, en cas de dÈtention d'une participation de plus de 10%, de transfÈrer des dividendes en exonÈration d'impÙts ‡ une sociÈtÈ de Hong Kong, depuis une sociÈtÈ belge, ou inversement.
Le Luxembourg vient de conclure un accord du mÍme type avec Hong Kong, applicable ‡ partir du 1er janvier 2008 en ce qui concerne le Luxembourg et du 1er avril 2008 en ce qui concerne Hong Kong.
Ce traitÈ prÈvoit Ègalement une absence de toute retenue ‡ la source pour les sociÈtÈs dÈtenant une participation de 10% au moins dans une sociÈtÈ de l'autre Etat.
Une particularitÈ remarquable est qu'il n'est pas prÈvu d'exclusion pour les sociÈtÈs de gestion du patrimoine familial, alors que...
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