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| Status | Enacted Law |
| Law | Luxembourg has published draft legislation that would implement the OECD’s January 2026 Side-by-Side package, introduce the permanent Simplified ETR Safe Harbour and extend the Transitional CbCR Safe Harbour. Bill No. 8795 was deposited in the Luxembourg Chamber of Deputies on July 17. 2026. It would amend the Law of 22 December 2023 on minimum effective taxation, which implemented the EU Pillar Two Directive and introduced Luxembourg’s income inclusion rule, undertaxed profits rule and QDMTT. On December 19, 2025, the Luxembourg Official Gazette published: – a law to amend its Minimum Tax Law to provide for the January 2025 OECD Administrative Guidance and the EU DAC 9 GIR filing requirements: and – a Grand Ducal Regulation which includes the format of the GIR. On June 12, 2024, the Luxembourg Government published draft law amending the law of 22 December 2023 on the minimum effective taxation for multinational enterprise groups and large domestic groups. The draft law provides for a number of amendments in the December 2023 OECD Administrative Guidance. On October 31, 2024 additional amendments were made to the draft legislation to incorporate elements from the OECD June 2024 Administrative Guidance. The draft law was approved by Parliament on December 19, 2024 and published in the Official Gazette on December 23, 2024. On December 22, 2023, the Luxembourg Official Gazette published Law A864 to transpose the EU Minimum Tax Directive. Grand-Ducal Regulation of 22 December 2023 on the procedures for registration and deregistration, notification and filing of the information return for the supplementary tax with the Direct Tax Administration |
| Effective Date | Accounting periods beginning on or after December 31, 2023 |
| IIR | Yes (2024) |
| UTPR | Yes (2025) |
| QDMTT | Yes (2024) |
| Filing Deadlines | Standard |
| Safe Harbours | Transitional CbCR Safe Harbour; QDMTT Safe Harbour; Transitional UTPR Safe Harbour; Permanent Safe Harbour. |
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