On 17 July 2026, the Luxembourg Government submitted a draft law amending the Luxembourg Pillar Two Law of 22 December 2023, as amended, to Parliament.
The draft law is intended primarily to implement the OECD “side-by-side” solution, agreed at OECD level, as well as a number of additional safe harbours and simplifications relating to the application of the Pillar Two rules.
This package of measures responds to the need, identified within the framework of the international implementation of the Pillar Two rules, to facilitate the practical application of the system. In particular, the proposed measures are expected to be relevant for certain MNE groups, including US-parented groups, whose tax systems may interact with the Pillar Two framework.
In this ATOZ News, our Tax Partner, Andreas Medler, and our Chief Knowledge Officer, Marie Bentley, examine the key provisions of the draft law, together with their practical implications and underlying rationale.