The Draft Law applies an Income Inclusion Rule (IIR) and domestic minimum tax (intended to be a Qualified Domestic Minimum Top-Up Tax (QDMTT) for fiscal years beginning on or after December 31, 2023. An Under-Taxed Profits Rule (UTPR) applies for fiscal years beginning on or after December 31, 2024.
As expected, Luxembourg’s implementation of the GloBE rules closely follows the EU Minimum Tax Directive. However, very few aspects of the OECD Administrative Guidance are included in the Draft Law, particularly as regards the general GloBE calculation.
Key aspects of Luxembourg’s Draft Law include:
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