On 19 December 2024, the Luxembourg Parliament passed a law (the
“Amending Law”) which amends the law
of 22 December 2023 (the “Pillar Two
Law”) implementing the EU Directive of 15 December
2022 on ensuring a global minimum level of taxation for
multinational enterprise (“MNE”)
groups and large-scale domestic groups in the Union (known as the
“Pillar Two Directive”).
The Amending Law incorporates clarifications, interpretations
and additional technical provisions resulting from three sets of
administrative guidance published by the OECD/G20 Inclusive
Framework on Base Erosion Profit Shifting in 2023 and a fourth set
of administrative guidance to assist MNEs in navigating the Global
Anti-Base Erosion (“GloBE”) rules
published by the OECD on 17 June 2024 (referred together as the
“Agreed Administrative Guidance”).
