Luxembourg: Additional tax measures in law implementing DAC8
Including CRS, CbC, DAC6, and DAC7 changes
The Direct Tax Administration (ACD) described the additional tax measures introduced by the law enacted on March 27, 2026, implementing directive requiring the reporting and automatic exchange of tax information on transactions involving cryptoassets (DAC8):
- The amended law of March 29, 2013, on administrative cooperation in the field of taxation has been updated to broaden the scope of automatic exchange of information. It now includes income derived from life insurance products paid, upon the death of the insured, to beneficiaries resident in another EU member state. In addition, advance tax rulings concerning individuals are now subject to exchange where they relate to transactions or series of transactions exceeding €1.5 million, or when they concern the determination of tax residence.
- The amended law of December 18, 2015, on the CRS has been modified to include certain products not covered by the new cryptoasset framework. In particular, electronic money products and central bank digital currencies are now within its scope. The law also strengthens due diligence and reporting obligations for financial institutions.
- The amended law of December 23, 2016, on CbC reporting has been amended to designate the withholding tax office on interest as the competent authority (CA) to impose penalties for non-compliance with reporting and notification obligations.
- The amended law of March 25, 2020, on reportable cross-border arrangements (DAC6) has been clarified with respect to professional secrecy. Lawyers are now only required to notify their clients, while other intermediaries remain subject to broader notification obligations.
- Finally, the law of May 16, 2023, on reporting obligations for platform operators (DAC7) has been supplemented to allow the use of identification services provided by the EU or an EU member state to verify a seller’s identity and residence.
For more information, contact a KPMG tax professional in Luxembourg:
Sophie Boulanger | sophie.boulanger@kpmg.lu
Jean Kizito | jean.kizito@kpmg.lu