On 4 August 2023, the Luxembourg government released the text of the draft law transposing the Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union. This Directive implements the Global Anti-Base Erosion rules, also called “Pillar Two”, agreed upon by the OECD.
On 13 November 2023, the Luxembourg parliament published amendments proposed by the government to the draft Law.
These amendments provide for additional guidance and clarification, as well as additional complementary rules in line with OECD guidance on Pillar Two but unfortunately, do not address all the clarification needed.
On 20 December 2023, the law including all amendments proposed by the government was passed.
In compliance with the Directive, most of the provisions of the new law are expected to come into effect for fiscal years beginning on or after 31 December 2023, while others will come into effect for fiscal years beginning on or after 31 December 2024.
In this article, we describe selected amendments proposed by the government

ATOZ Insights: Analysis of the last provisions introduced by the government in the law transposing Pillar Two