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ARTICLE · 18 MAY 2023

Pillar II – Impact On Investment Fund Managers

Atoz Tax Advisers
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The Global Anti-Base Erosion ("GloBE") rules, also called "Pillar Two", provide for a coordinated system of taxation..

LuxembourgFinance and Banking
Andreas Medler
Andreas Medler

OUR INSIGHTS AT A GLANCE

  • The Global Anti-Base Erosion rules, also called "Pillar Two", provide for a coordinated system of taxation intended to ensure that large multinational enterprise groups pay a minimum level of tax (15%) on the income arising in each of the jurisdictions where they operate.
  • On 15 December 2022, the Council of the European Union formally adopted the Pillar Two Directive. Luxembourg, like any other EU Member State, has to transpose the Directive into its domestic law by 31 December 2023 at the latest. The new rules will apply to tax years starting on or after 31 December 2023, so as from 1 January 2024 in most cases, which leaves very little time to adapt.

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