Luxembourg’s Parliament is considering a bill to amend the law implementing the OECD/G20 Pillar Two global minimum tax rules. The proposal would introduce new safe harbors, including a permanent side-by-side safe harbor, a qualified ultimate parent entity safe harbor, a qualified tax incentives safe harbor, and a simplified effective tax rate safe harbor. It would also extend the transitional country-by-country reporting safe harbor by one year.
On 5 June 2026, Luxembourg’s Luxembourg Inland Revenue updated its FAQs on OECD Pillar Two compliance for multinational and large domestic groups. The guidance provides further clarification on registration and reporting obligations, including rules for newly created or dissolved entities, exemptions from filing the GloBE Information Return, and the treatment of deferred taxes during the transition period. It also confirms how deferred tax assets and liabilities may be reported for purposes of transitional relief.
On 16 March 2026, Luxembourg published an updated list of jurisdictions participating in the exchange of country-by-country (CbC) reports for multinational enterprise groups. The updated regulation will enter into force on 20 March 2026.
On December 17, 2024 Luxembourg’s parliament approved amendments to its global minimum tax implementation, focusing on how top-up taxes will be handled. The amendments, passed with 58 votes in favor and two abstentions, align with the OECD’s updated guidance issued in June. Under the changes, Luxembourg chose an option allowing any top-up tax liabilities arising from securitization vehicles to be allocated to other Luxembourg entities. These vehicles fall under the OECD’s definition of securitization entities. Additional updates clarify how the GloBE model rules apply to flow-through and hybrid entities. The amendments will apply retroactively to fiscal years starting on or after December 31, 2023. The bill now awaits review by the Council of State, with a request to bypass a second parliamentary vote, allowing direct approval by the Duke upon Council consent.
To learn more on the amendments, you can access the Bill by clicking here.