Key implementation point
Major fund-domicile jurisdiction: extensive analysis required on which fund structures fall within GloBE scope.
Implementation detail
- 01 Luxembourg enacted IIR and QDMTT; UTPR not included in first wave.
- 02 Significant impact: Luxembourg is a major holding and fund jurisdiction with many large MNE structures.
- 03 Luxembourg QDMTT ensures top-up is collected locally rather than by Luxembourg UPE's jurisdiction.
- 04 Investment funds and their subsidiary entities: GloBE exclusions for regulated funds carefully scoped.
- 05 Administration Contributions Directes (ACD) issued detailed implementation circulars.
Enacted legislation
Loi du 22 décembre 2023
Official sources & further reading
Track Luxembourg rules against your live MNE
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