On 17 December 2025, the Luxembourg Parliament enacted the law on the exchange of information with respect to “top-up tax information return”, which transposes Directive (EU) 2025/872 also called DAC9. This new law amends the law of 22 December 2023 implementing Directive (EU) 2022/2523 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the European Union, known as the Pillar Two Directive.
The new law aims to facilitate compliance with the filing obligations of companies under the Pillar Two Directive and to align Luxembourg rules with recent OECD Administrative Guidance.
The obligation to prepare a “top-up tax information return”, also named “GloBE Information Return” or “GIR”, is distinct from the requirement to declare and pay Luxembourg top-up taxes under a Luxembourg tax return. The new law does not prevent Luxembourg constituent entities to file such Income Inclusion Rule, Undertaxed Profits Rule or Qualified Domestic Top-up Tax returns in Luxembourg, as required under the Luxembourg Law.
In this Alert, our Tax Partner, Andreas Medler, describes the main provisions of the new law and their implications for Luxembourg constitutive entities of multinational enterprise groups in the scope of Pillar Two.