ARTICLE · 24 AUGUST 2023

Implementation Of Pillar 2: 15% Minimum Tax Coming Soon For Multinationals

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On 28 July 2023, the Grand Duchy of Luxembourg announced that it had given its assent to the bill aimed at transposing the directive 2022/2523 of 14 December 2022 (the « Directive »)...

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On 28 July 2023, the Grand Duchy of Luxembourg announced that it had given its assent to the bill aimed at transposing the directive 2022/2523 of 14 December 2022 (the « Directive ») commonly known as "Pillar 2" into its national law. The Directive introduces new tax measures establishing a worldwide minimum level of taxation, as desired by the OECD.

The bill n°8292 was therefore submitted to the Chambre des Députés on 4 August 2023. This bill, which transposes Pillar 2, aims to limit competition based on corporate income tax rates by introducing a worldwide minimum tax rate of 15%. In order to achieve this ambitious objective, Pillar 2 proposes two elements, (i) global anti base erosion rules ("GloBE") and (ii) the qualified domestic top-up tax.

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