Luxembourg: Updated CRS guidance

FAQs for Luxembourg financial institutions under the CRS

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november 4, 2025

The Luxembourg tax authorities on November 3, 2025, updated frequently asked questions (FAQs) related to the common reporting standard (CRS) that may impact financial institutions' compliance obligations and procedures.

The updated FAQs introduce new and revised guidance for Luxembourg financial institutions under the CRS. The changes include:

  • The obligation to notify the Luxembourg tax authorities of any change in CRS entity status by June 30 of the following year
  • Expanded record-keeping duties that require institutions to retain all client files, CRS reports, procedures, and supporting evidence even when using service providers, and include clear expectations for maintaining a “Register of Actions” documenting compliance activities

The FAQs also detail three types of CRS audits conducted by the Luxembourg tax authorities and outline the audit process from notification to final recommendations.

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

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