www.ey.com
Open in
urlscan Pro
2620:1ec:bdf::40
Public Scan
URL:
https://www.ey.com/en_lu/insights/tax/luxembourg-parliament-enacts-changes-to-pillar-two-law
Submission: On December 21 via api from US — Scanned from US
Submission: On December 21 via api from US — Scanned from US
Form analysis
0 forms found in the DOMText Content
Skip to content EY Logo * Insights * Technology * Transformation * Long-term value * Sustainability * Trust * Purpose * Services * Strategy by EY-Parthenon * Digital strategy consulting * Commercial strategy consulting * More about EY-Parthenon * Strategy consulting services * Corporate and growth strategy * Transaction strategy and execution * Restructuring and turnaround strategy * Consulting * Customer experience * Cyber Risk, Compliance and Resilience Services * Data and decision intelligence * Risk consulting services * Supply chain and operations * Technology leaders’ agenda * Transformation EQ * Transformation Platform * People and workforce * Change management and experience services * HR Transformation Services * Integrated workforce mobility * Learning and development consulting * Recognition and reward advisory * Workforce analytics * Transactions and corporate finance * Value creation, preservation and recovery * Corporate finance * Divestment strategy: sell and separate * Sustainability and ESG Services * M&A Advisory | Buy and Integrate * M&A integration * Connected Capital Technologies: M&A technology solutions * Advanced analytics * Capital allocation * Assurance * Technology Risk * Audit * Climate change and sustainability services * Financial accounting advisory services * Forensic and Integrity Services * Private client audit experience * Long-term value metrics creation * IFRS * Tax * Tax planning * Tax operating model strategy and transformation | EY – Global * Tax policy and controversy * Global trade * Global tax reform * Tax compliance * Transaction tax * Tax services: Designed for private * Law * Corporate and commercial law * Digital law * Labor and employment law * Legal operations * Transaction law * Technology * Technology Managed Services * EY.ai * Audit technology * Tax technology * Connected Capital Technologies: M&A technology solutions * Technology transformation * Alliances * Managed Services * Technology Managed Services * Cybersecurity Managed Services * Tax Managed Services * Financial Accounting & Corporate Reporting Managed Services * Sustainability Managed Services * Risk Managed Services * Legal Managed Services * EY Private * EY Private client experience * EY private client audit experience service offerings * Tax services: Designed for private * Family enterprise * IPO * Entrepreneurship * EY Sustainability * Climate change and sustainability services * Sustainable finance * ESG strategy services * Supply chain transformation * Sustainability tax services * Legal services * Global renewables * Climate and decarbonization * Environment, Health and Safety * Industries * Advanced manufacturing and mobility * Aerospace and defense * Automotive * Chemicals and advanced materials * EY-Nottingham spirk innovation hub * Future mobility * Industrial products * Mobility lens suite * Transportation * Consumer products * Consumer products * Retail * The future consumer * Sustainability * Energy and resources * Mining & Metals – Our latest thinking * Oil & Gas – Our latest thinking * Power and utilities * Strategy consulting * Financial services * Banking and capital markets * Insurance * Wealth and asset management * Sustainable finance * Fintech and ecosystems * Government and infrastructure * Data and technology * Education * Human services * Infrastructure * Public finance management * Private equity * Private equity value creation services * Exit readiness * PE deal origination * Digital in private equity * Health * Life Sciences * Health * Technology, media & entertainment, and telecommunications * Technology, media & entertainment, and telecommunications * Technology sector * Telecommunications sector | Insights, surveys & services * As-a-service business operations and transformation * TMT business resiliency suite * Future network now * Capital operations and innovation suite (COInS) * Careers * What you can do here * Careers in Tech * Careers in Core Business Services * Careers in Assurance * Careers in Consulting * Careers in EY-Parthenon * Careers in Strategy and Transactions * Careers in Tax * Careers in People Advisory Services * Careers in Financial Services * Careers in Global Delivery Services * What it's like to work here * Diversity, equity and inclusiveness * Personalized career development * Flexibility and mobility * People stories * How to join us * How we hire * Interview tips * What we look for * Job search * Job search * Students and entry-level * Contract opportunities * Talent community * About us * Our purpose * Newsroom * Our values * Our people * Locations * Connect with us * Alumni Back INSIGHTS Read More Read Less Asking the better questions that unlock new answers to the working world's most complex issues. Read More Read Less Explore TRENDING TOPICS Read More Read Less See more Read More Read Less See more Read More Read Less SPOTLIGHT Read More Read Less AI insights CEO agenda CFO agenda EY Center for Board Matters EY podcasts EY webcasts Operations leaders Technology leaders See more Read More Read Less Back SERVICES Read More Read Less EY helps clients create long-term value for all stakeholders. Enabled by data and technology, our services and solutions provide trust through assurance and help clients transform, grow and operate. Read More Read Less Explore See more Read More Read Less SPOTLIGHT Read More Read Less EY.ai - A unifying platform Strategy, transaction and transformation consulting Technology transformation Tax function operations Climate change and sustainability services EY Ecosystems EY Nexus: business transformation platform Read More Read Less Back INDUSTRIES Read More Read Less Discover how EY insights and services are helping to reframe the future of your industry. Read More Read Less Explore See more Read More Read Less CASE STUDIES Read More Read Less Workforce How Microsoft built a new mobility model for cross-border talent 13 May 2024EY Global Private equity How GenAI is empowering talent at a PE-backed consumer brand 08 May 2024EY Global Strategy and Transactions How carve-outs positioned an automotive giant for future growth 11 Apr 2024EY Global -------------------------------------------------------------------------------- See all Read More Read Less Back CAREERS Read More Read Less We bring together extraordinary people, like you, to build a better working world. Read More Read Less Explore See more Read More Read Less SPOTLIGHT Read More Read Less Experienced professionals EY-Parthenon careers Student and entry level programs Talent community Read More Read Less Back ABOUT US Read More Read Less At EY, our purpose is building a better working world. The insights and services we provide help to create long-term value for clients, people and society, and to build trust in the capital markets. Read More Read Less Explore See more Read More Read Less TOP NEWS Read More Read Less Press release Vellayan Subbiah from India named EY World Entrepreneur Of The Year™ 2024 06 Jun 2024Eric J. Minuskin Press release Startup World Cup – 10 startups will be pitching for their ticket to Silicon Valley 06 May 2024Julien Delpy Search search close search See all results for ' ' No results have been found Topics See All General See All People See All Recent Searches Trending * How can you shape your IPO with confidence? The EY Global IPO Trends Q3 2024 covers the news and insights on the global, area and regional IPO markets for Q3 and year-to-date 2024. Find out more. 25 Sep 2024 Private business * How can the moments that threaten your transformation define its success? Leaders that put humans at the center to navigate turning points are 12 times more likely to significantly improve transformation performance. Learn More. 15 Apr 2024 Consulting * Artificial Intelligence EY.ai - a unifying platform 16 Nov 2023 AI My EY My EY Luxembourg English Select your location close LuxembourgEnglishdone GlobalEnglish Local sites AlbaniaEnglish AlgeriaEnglish AngolaEnglish Angolaportuguês Argentinaespañol ArmeniaEnglish ArubaEnglish AustraliaEnglish AustriaDeutsch AzerbaijanEnglish BahamasEnglish BahrainEnglish BangladeshEnglish BarbadosEnglish BelgiumEnglish BelgiumNederlands Belgiumfrançais BermudaEnglish Boliviaespañol Bosnia-HerzegovinaEnglish BotswanaEnglish BrazilEnglish Brazilportuguês British Virgin IslandsEnglish BruneiEnglish BulgariaEnglish Bulgariaбългарски CambodiaEnglish CameroonEnglish CanadaEnglish Canadafrançais Cayman IslandsEnglish Central AmericaEnglish Costa RicaEnglish NicaraguaEnglish HondurasEnglish GuatemalaEnglish El SalvadorEnglish PanamaEnglish Dominican RepublicEnglish ChadEnglish Channel IslandsEnglish Chileespañol ChinaEnglish China中文 Central Americaespañol Costa Ricaespañol Nicaraguaespañol Hondurasespañol Guatemalaespañol El Salvadorespañol Panamaespañol Dominican Republicespañol Colombiaespañol CongoEnglish CroatiaEnglish Croatiahrvatski CuracaoEnglish CyprusEnglish Czech RepublicEnglish Czech Republicčeština Democratic Republic of the CongoEnglish DenmarkEnglish Denmarkdansk Ecuadorespañol EgyptEnglish Equatorial GuineaEnglish EstoniaEnglish Estoniaeesti FijiEnglish Finlandsuomi Finland EnglishEnglish Francefrançais Francophone AfricaEnglish GabonEnglish GeorgiaEnglish GermanyDeutsch GhanaEnglish GibraltarEnglish GreeceEnglish GreeceΕλληνικά GuamEnglish GuernseyEnglish GuineaEnglish GuyanaEnglish Hong Kong SAREnglish Hong Kong SAR中文 HungaryEnglish Hungarymagyar IndiaEnglish IndonesiaEnglish IraqEnglish IrelandEnglish Isle of ManEnglish IsraelEnglish ItalyEnglish Italyitaliano Ivory CoastEnglish JamaicaEnglish JapanEnglish Japan日本語 JordanEnglish KazakhstanEnglish Kazakhstanрусский KenyaEnglish KoreaEnglish Korea한국어 KuwaitEnglish Kyrgyz RepublicEnglish LaosEnglish LatviaEnglish Latvialatviešu LebanonEnglish LibyaEnglish LithuaniaEnglish Lithuanialietuvių Macau SAREnglish Macau SAR中文 MalawiEnglish MalaysiaEnglish MaldivesEnglish MaltaEnglish MauritiusEnglish Mexicoespañol Middle East and North AfricaEnglish MoldovaEnglish MongoliaEnglish MontenegroEnglish MoroccoEnglish MozambiqueEnglish Moçambiqueportuguês MyanmarEnglish NamibiaEnglish NetherlandsEnglish NetherlandsNederlands New ZealandEnglish NigeriaEnglish North MacedoniaEnglish NorwayEnglish Norwaynorsk OmanEnglish PakistanEnglish Palestinian AuthorityEnglish Papua New GuineaEnglish Paraguayespañol Peruespañol PhilippinesEnglish PolandEnglish Polandpolski PortugalEnglish Portugalportuguês QatarEnglish RomaniaEnglish Romaniaromână RwandaEnglish Saint LuciaEnglish SaipanEnglish Saudi ArabiaEnglish SenegalEnglish SerbiaEnglish Serbiaсрпски SingaporeEnglish Slovak RepublicEnglish Slovak Republicslovenčina SloveniaEnglish Sloveniaslovenščina South AfricaEnglish SpainEnglish Spainespañol Sri LankaEnglish SurinameEnglish SwedenEnglish Swedensvenska SwitzerlandDeutsch SwitzerlandEnglish Switzerlandfrançais SyriaEnglish TaiwanEnglish Taiwan中文 TanzaniaEnglish ThailandEnglish Trinidad and TobagoEnglish TunisiaEnglish Tunisiafrançais Türkiye (Turkey)English Türkiye (Turkey)Türkçe UgandaEnglish UkraineEnglish Ukraineукраїнська United Arab EmiratesEnglish United KingdomEnglish United StatesEnglish Uruguayespañol UzbekistanEnglish Venezuelaespañol VietnamEnglish VietnamTiếng Việt ZambiaEnglish ZimbabweEnglish LUXEMBOURG PARLIAMENT ENACTS CHANGES TO PILLAR TWO LAW Authors * Bart Van Droogenbroek EY Luxembourg Partner, Tax Leader * Christian Schlesser EY Luxembourg Partner, International Tax and Transactions Services Leader 3 minute read 19 Dec 2024 Related topics Tax * Facebook * Twitter * LinkedIn * Link Copied Show resources * On 19 December 2024, the Luxembourg Parliament approved a legislative proposal1 that will amend the law dated 22 December 2023 (Pillar Two Law). * While there are still some formal legal steps that need to be taken before the proposals become law, these steps are expected to occur before year-end. Read More Read Less -------------------------------------------------------------------------------- DISCUSSION On 19 December 2024, the Luxembourg Parliament adopted legislation amending the Pillar Two Law. The new legislation aims to incorporate, with effect for financial years starting from 31 December 2023, clarifications and additional provisions of the Organisation for Economic Co-operation and Development (OECD) Guidance issued in February 2023, July 2023, December 2023 and June 2024, without going beyond the guidance. Among other things, the new legislation extends the scope of Excluded Entities, adapts certain provisions related to the Qualified Domestic Top-up Tax (QDMTT) and clarifies the application of the Transitional Country-by-Country Reporting (CbCR) safe harbor. Additionally, it outlines Luxembourg’s choice on the Pillar Two treatment of securitization entities. Furthermore, the legislation implements guidance on the allocation of profits and taxes involving Flow-through Entities and provides a framework for a more detailed implementation (through decrees that still need to be issued) of the OECD Guidance on deferred tax liability recapture, divergence between Global Anti-Base Erosion (GloBE) and accounting carrying values and the allocation of cross-border current and deferred taxes. Earlier in the year, Luxembourg government issued two draft decrees implementing the OECD Guidance on tax credits and on functional currency to be used for the Pillar Two computations. These two draft decrees have also passed the necessary legislative steps in Luxembourg and are expected to be signed and published before the end of the year. NEXT STEPS The final law and decrees are expected to be published in the Official Gazette before year-end, with entry into effect for tax years starting on or after 31 December 2023. Taxpayers potentially affected by the new legislation should consult with their tax advisors to fully understand how the change in law could affect them. Read More Read Less Show references Hide references 1. See EY Luxembourg Tax Alert, Luxembourg updates draft legislation amending Pillar Two Law reflecting June 2024 OECD guidance | EY Luxembourg, dated 7 November 2024 and Luxembourg proposes changes to Pillar Two Law | EY - Global, dated 12 June 2024. SUMMARY On 19 December 2024, the Luxembourg Parliament approved a legislative proposal that will amend the law dated 22 December 2023 (Pillar Two Law). Read More Read Less About this article Authors * Bart Van Droogenbroek EY Luxembourg Partner, Tax Leader * Christian Schlesser EY Luxembourg Partner, International Tax and Transactions Services Leader Related topics Tax * Facebook * Twitter * LinkedIn * Link Copied -------------------------------------------------------------------------------- EY logo * Connect with us * Our locations * My EY * Site map * Legal and privacy Read More Read Less * Open Facebook profile * Open X profile * Open LinkedIn profile * Open Youtube profile EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. modal-close-button Welcome to EY Luxembourg (EN) You are visiting EY lu (en) lu en Welcome to EY.com In addition to cookies that are strictly necessary to operate this website, we use the following types of cookies to improve your experience and our services: Functional cookies to enhance your experience (e.g. remember settings), Performance cookies to measure the website's performance and improve your experience, and Marketing/Targeting cookies, which are set by third parties, allow us to execute marketing campaigns, manage our relationship with you, build a profile of your interests and provide you with content or service offerings in accordance with your preferences. You may withdraw your consent to cookies at any time once you have entered the website through a link in the cookie policy, which you can find at the bottom of each page on the website in the ‘Legal and Privacy’ section. Review our cookie policy for more information. I decline optional cookies I accept all cookies Customize cookies COOKIE SETTINGS Please provide your consent for cookie usage on ey.com and the My EY platform. Select one or more of the cookie types listed below, and then save your selection(s). Refer to ‘Cookie Details’ for each cookie type for details on the cookies and their purpose. Review our Cookie Policy for more information MANAGE CONSENT PREFERENCES REQUIRED/MANDATORY COOKIES Active These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. Cookie details FUNCTIONAL COOKIES Functional Cookies Functionality cookies, which allow us to enhance your experience (for example by remembering any settings you may have selected). Cookie details PERFORMANCE COOKIES Performance Cookies Performance cookies, which help us measure the website’s performance and improve your experience. In using performance cookies we do not store any personal data, and only use the information collected through these cookies in aggregated and anonymized form. Cookie details MARKETING/TARGETING COOKIES Marketing/Targeting Cookies Marketing/targeting cookies, which we use to track user activity and sessions so that we can deliver a more personalized service. Marketing cookies are set by third parties with whom we execute marketing campaigns and allow us to provide marketing relevant to you. If you identify yourself to us (e.g. filling out a form/signing up to receive email updates), EY collects information about your response to our marketing communications and your activity on this website. This information is added to your personal marketing profile and score which is used to measure campaign effectiveness and to provide content and offer services that are relevant for you. Cookie details Back Button COOKIE LIST Search Icon Filter Icon Clear checkbox label label Apply Cancel Consent Leg.Interest checkbox label label checkbox label label checkbox label label Save My Selection