Pillar Two: The OECD grants Luxembourg the transitional qualified status and releases new guidance on deferred tax assets and the GloBE Information Return

On 15 January 2025, the OECD published the list of countries that have already implemented the Global Anti-Base Erosion (GloBE) Model Rules, also known as Pillar Two, introducing a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups. The list details the jurisdictions whose legislation is considered to comply with the OECD framework. Luxembourg is on that list.

In addition, the OECD released new guidance addressing the treatment of certain deferred tax assets that arose prior to the application of the global minimum tax under Pillar Two as a result of certain governmental arrangements or following the introduction of a new corporate income tax. It also published updates to the GloBE Information Return released in July 2023 to facilitate compliance with and administration of the GloBE Model Rules.

Our Tax Partner, Andreas Medler, shares an in-depth analysis of the transitional qualified status for Luxembourg and the new OECD guidance on deferred tax assets.