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ARTICLE · 20 APRIL 2026

ATOZ Insights - April 2026

Atoz Tax Advisers
Atoz Tax Advisers
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Atoz Tax Advisers

Atoz Tax Advisers

Our firm Founded in 2004, ATOZ Tax Advisers is a leading independent tax advisory firm offering a...

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ATOZ provides comprehensive tax and legal advisory services with a focus on personalized client relationships and pragmatic solutions. The firm publishes regular insights covering international tax developments, regulatory updates, and business guidance across multiple jurisdictions including Luxembourg, UAE, and EU member states.

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Atoz Tax Advisers
Atoz Tax Advisers

We have already enjoyed early spring days, so it’s time for our first 2026 ATOZ Insights.

On 6 January 2026, the Luxembourg tax authorities launched online procedures via MyGuichet.lu for Pillar Two compliance. We outline the key obligations for Luxembourg constituent entities, including mandatory registration, GloBE Information Return filings and Top‑up Tax Return procedures.

We also analyse the permanent establishment risks arising from cross‑border remote work for Luxembourg businesses, focusing initially on the OECD’s 2025 Commentaries regarding the assessment of a fixed place of business and subsequently on the dependent agent rules.

We then delve into the evolving concept of beneficial ownership, analysing its key role in accessing treaty and EU directive benefits, as well as recent case law trends emphasising substance, control and economic reality.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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