On 19 December 2024, the Luxembourg Parliament passed a new law which amends the law of 22 December 2023 implementing the EU Directive of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union, known as the Pillar Two Directive.
The new law incorporates clarifications, interpretations and additional technical provisions resulting from three sets of administrative guidance published by the OECD/G20 Inclusive Framework on BEPS in 2023 and a fourth set of administrative guidance to assist multinational enterprises in navigating the Global Anti-Base Erosion rules published by the OECD on 17 June 2024.
Our Tax Partner, Andreas Medler, and Chief Knowledge Officer, Marie Bentley, describe some of the main clarifications for Luxembourg funds hereafter.