GloBE Country Guide: Luxembourg

Summary

Status	Enacted Law
Law	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. 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.

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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