Luxembourg: Draft legislation to implement DAC9, amend Pillar Two rules to incorporate recent OECD guidance

Bill No. 8591 submitted to Parliament on July 24, 2025

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August 1, 2025

The government on July 24, 2025, submitted Bill No. 8591 to the Parliament—draft legislation to transpose Council Directive (EU) 2025/872 (facilitating the automatic exchange of Pillar Two information between EU member states) (DAC9) into domestic law effective January 1, 2026, and to incorporate certain elements of the OECD’s Administrative Guidance on Pillar Two published in January 2025.

In addition, a new draft Grand-Ducal regulation on Article 50 of the Pillar Two Law was issued to introduce the standard form of the GloBE information return (GIR) to be used by Luxembourg constituent entities in line with the Annex to DAC9.

Read a July 2025 report prepared by the KPMG member firm in Luxembourg

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