
The Grand-Ducal Decree added the following jurisdictions to the List of Participating Jurisdictions. In addition, certain jurisdictions were added to the list of Reportable Jurisdictions.
In detail
The following Participating Jurisdictions were added:
- Armenia
- Georgia
- Moldova
- Ukraine
These jurisdictions formally committed to implement the CRS either by signing the relevant Multilateral Competent Authority Agreement (“MCAA”) or by entering into bilateral agreements with Luxembourg for the purpose of the same. This impacts the due diligence obligations regarding the application of the “deemed Passive NFE” concept under the CRS Law.
The following jurisdictions have been added to the List of Reportable Jurisdictions:
- Armenia
- Rwanda
- Senegal
For the calendar year 2024 CRS reporting (due on 30 June 2025 at the latest), reportable persons tax resident in these countries will consequently need to be reported (and, where reportable individuals/controlling persons are concerned, be notified sufficiently in advance of the reporting through a specific notification).
Our observations
Following the modifications of the list of CRS Participating and Reportable Jurisdictions, Reporting FI’s need to quickly act to take into account the changes for the calendar year 2024 reporting (or undertake corrective action should reporting already have taken place).
For any questions, please feel free to be in touch with your usual Grant Thornton contacts, or our specialist team mentioned hereafter.