Pillar Two law passed by Luxembourg Parliament
On 20 December 2023, the Luxembourg Parliament adopted bill of law 8292 implementing Council Directive (EU) 2022/2523 dated 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the EU, commonly known as Pillar Two (the “Bill”). The Bill has been published in the Luxembourg official gazette on 22 December 2023.
The income inclusion rule (IIR) and qualified domestic minimum top-up tax (QDMTT) will apply to tax years starting on or after 31 December 2023. The provisions of the undertaxed payments rule (UTPR) which will in principle apply to tax years starting on or after 31 December 2024.
It is not excluded that the Bill be amended in the future to take into account the technical guidance provided by the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) released on 18 December 2024.
Our tax team is available to assess the potential impacts of these rules on your operations.
