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GloBE Country Guide: Luxembourg

Summary

Status Enacted Law
LawOn 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.

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 DateAccounting periods beginning on or after December 31, 2023
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursTransitional CbCR Safe Harbour;

QDMTT Safe Harbour;

Transitional UTPR Safe Harbour;

Permanent Safe Harbour.

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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