Luxembourg Publishes Bill Of Law To Implement Pillar Two

On 4 August 2023, Luxembourg published a bill of law (the Luxembourg Bill) to transpose the EU directive implementing the minimum taxation (Pillar Two) (the Directive) into domestic law as per 31 December 2023.

Some guidelines and solutions released by the OECD after the adoption of the directive in December 2022 were taken into account, notably transitional safe harbours based on country-by-country reporting data. The bill also confirms that OECD guidance in connection with the OECD Model Rules is relevant.

Background

The OECD's Pillar Two project aims to ensure that Multinational Enterprises (MNE) groups meeting the EUR 750 million consolidated revenue threshold are always subject to a minimum corporate taxation of 15%. Much progress has been made in the past 18 months: