Read our insights

On 17 February 2026, the EU Council published the updated list of non-cooperative jurisdictions for tax purposes (“Blacklist”), adding two new countries (Turks and Caicos Islands and Viet Nam) and removing three countries from the list (Fiji, Samoa and Trinidad and Tobago). It is now composed of 10 jurisdictions, with the next revision due in October 2026.

This publication is designed to give preparers and reviewers of IFRS financial statements a high-level awareness of recent changes to International Financial Reporting Standards. It covers both new Standards and Interpretations that have been issued and amendments made to existing ones.

The key amendments, that mostly concerns transfer pricing aspects, are the modifications made to the General Law on Taxation of the 22 May 1931 (“Abgabenordnung”) in the following paragraphs: §29c, §96a, §171 ,§165c & §249. These changes have been made with a view to simplifying and modernising the procedures applicable to taxpayers.

Understanding Taiwan’s Double Tax Agreements - A Foreign Entity invested in Taiwan may apply for withholding tax reclamation or tax relief if it is domiciled in a country that has a Double Tax Agreement with Taiwan.

On 14th May 2024, the EU Council adopted the EU Directive on Faster and Safer Relief of Excess Withholding Taxes (“FASTER”).

The Grand-Ducal Decree of 18 April 2024 modified the lists of Participating Jurisdictions and Reporting Jurisdictions for the CRS reporting year 2023.

Following the transposition into Luxembourg national law of the EU Directive 2022/2523 (the "Pillar 2 Law"), multinational enterprise (MNE) groups and significant large domestic groups are required to pay a minimum tax level of 15%. The Pillar 2 law came into effect for fiscal years starting on or after 31 December 2023.

Recent decisions rendered by the Court of Justice of the European Union (“CJEU”) seem to have put an end to investigations of the European Commission (“EC”) into tax measures of the Member States based on the state aid rules. In particular, certain tax rulings granted by the Luxembourg tax authority (“LTA”) to Fiat, Engie and Amazon groups have been characterised by the EC in the past as conveying illegal selective tax advantages. Ultimately, CJEU decisions rendered in these cases found the tax rulings not to constitute unlawful state aid.

On 20 December 2023, draft law no. 8292 (“Draft Law”), transposing the EU Council Directive 2022/2523 of 14 December 2022 (“Pillar Two Directive”) into Luxembourg national law, was adopted by the Luxembourg Parliament (the “Law”). The Law aims to ensure that multinational enterprise (“MNE”) groups and significant large domestic groups pay a minimum level of tax of 15%. It incorporates amendments proposed by the Luxembourg Government in November 2023 in order to be aligned with administrative guidance issued by the OECD.

On 22 December, the Administration de l’enregistrement, des domaines et de la TVA (“AEDT”) has issued circular no 781-1 on VAT on directors’ fees.

Following the CJEU’s decision C-288/19, “QM” of January 20th, 2021, the VAT treatment of company cars granted by a company to its employees should be modified for most cases applied by Luxembourg companies. Following this “QM” case-law, in the event where a company provides company cars to its employees, and provided the below conditions are met, this supply corresponds to a VAT taxable activity on which VAT must be collected by the company and accordingly declared to the VAT Authorities

The law of August 7, 2023 on non-profit associations and foundations was published in the Official Journal on September 19, 2023 and come into force since September 23, 2023. It applies to newly created non-profit organisations and foundations from this date.

On 12 September 2023, the European Commission adopted the proposal for a directive “Business in Europe: Framework for Income Taxation. BEFIT aims to introduce a single set of rules applicable to determine the corporate income tax base of multinational enterprises in all EU Member States as well as a simplified transfer pricing approach for assessing intercompany transactions. In the words of the EC, the Proposal is motivated by reduction of tax compliance costs for large, cross-border businesses in the European Union.

On 4 August 2023, the Luxembourg Government introduced to the Luxembourg Parliament the draft law no. 8292 (the "Draft Law"), aimed at implementing the provisions of the European Union (“EU”) Council Directive 2022/2523 of 14 December 2022 (the “EU Pillar Two Directive” or the “Directive”). In line with the Directive, and in order to ensure that large multinational enterprise (“MNE”) groups and significant large domestic groups pay a minimum level of tax, the Draft Law introduces three new taxes into Luxembourg national law.

On 13 July 2023, the Luxembourg Government presented the draft law no. 8276 to the Luxembourg Parliament. The Draft Law proposes changes to the current investment tax credit regime by increasing the rates of the global ITC and introducing a new ITC for investments and expenses related to the digital transformation and the ecological and energy transition. The proposed measures are planned to apply as from tax year 2024.

On 30 June 2023, the Luxembourg tax authority issued the updated guidance in form of an FAQ (the “Guidance”) on the law implementing the EU Directive on the mandatory disclosure rules and exchange of cross-border tax arrangements (“DAC 6”). The Guidance contains welcome clarifications concerning hallmarks C1 and E3, as well as an explanation regarding the notification obligations of persons covered by the legal professional privilege.