Luxembourg: Updated CRS FAQs

The Luxembourg tax authority on October 29, 2025, released an updated version of its frequently asked questions (FAQs) under the common reporting standard (CRS) regime. The key updates are as follows:

• Section 2 – Financial institutions: A new question (2.7) has been added regarding whether the Interest Withholding Tax Office (SRI) must be notified in the event of a change in entity status under the CRS law.
• Section 4 – Due diligence: A new note has been added to question 4.4 regarding the specific procedures for collecting and validating self-certifications when opening new accounts.
• Section 5 – Declaration / reporting: Question 5.5, which addresses the procedure to follow when a reporting financial institution does not have a Luxembourg tax identification number (NIF), has been updated.
• Section 6 – Retention / archiving obligation: Question 6.1 addresses the retention obligations of reporting financial institutions as prescribed in Article 2(1) of the CRS law.
• Section 7 – Compliance with the obligations under Article 2(1) of the CRS law:
  • Question 7.1 describes the required contents of the register of actions taken. While no specific format is mandated, reporting financial institutions must log all actions during the reporting year.
  • Question 7.2 outlines the compliance checks performed by the SRI for CRS and FATCA.
  • Question 7.3 details the procedure for in-depth audits by SRI.

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