Initiated by the OECD and embraced by more than 140 countries, Pillar Two rules were released in December 2021, adopted by a European Directive in December 2022, and transposed into Luxembourg law in December 2023. These rules (along with accompanying acronyms) mark a significant shift in the international taxation of multinationals worldwide, including those operating within or through Luxembourg. It is anticipated that these changes will have an impact in the Luxembourg economy. 

Pillar Two in a nutshell

Continuous monitoring 

To provide temporary operational relief to in-scope Groups, Transitional Safe Harbours are available, leveraging from Country-by-Country Report (CbCR) and financial statements data. If one of the relevant tests is met in a country, the Group will not need to conduct a full Pillar Two calculation (for that country).

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