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By Pierre-Régis DUKMEDJIAN, Founder DPR Tax Law
On 12 June 2024, a new bill of law (8396) (“the Bill of Law”) was introduced, amending the Law of 22 December 2023 implementing Pillar Two, i.e., the global minimum taxation rules (“Pillar Two Law”). The Bill of Law provides for numerous amendments to the Pillar Two Law, to mainly include parts of the OECD administrative guidance issued in February, July and December 2023.
Pillar Two Law implements into Luxembourg domestic law the Council Directive (EU) 2022/2523 of 15 December 2022 and introduces into Luxembourg law a minimum of 15% of effective tax rate for group of companies with a consolidated turnover of equal or greater than EUR 750 million.
Some aspects of the proposed...
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