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By Nicolas DEVERGNE, International Tax Partner, Deloitte Luxembourg Dachelina ABDULKADIROVA, Assistant Manager, International Tax, Deloitte Luxembourg
On 5 January 2026, the OECD/G20 Inclusive Framework on BEPS published the anticipated “side-by-side package” providing for various measures and allowing the US system to sit alongside the Pillar Two framework. As part of this document, the newly introduced permanent substance-based tax incentive (SBTI) safe harbor may be of particular interest to Luxembourg taxpayers since it should allow certain qualified tax incentives (QTIs) to be treated as additions to covered taxes once the safe harbor is implemented in the Luxembourg domestic legislation.
The anticipated introduction of this new...
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