On December 17, 2024 Luxembourg’s parliament approved amendments to its global minimum tax implementation, focusing on how top-up taxes will be handled. The amendments, passed with 58 votes in favor and two abstentions, align with the OECD’s updated guidance issued in June. Under the changes, Luxembourg chose an option allowing any top-up tax liabilities arising from securitization vehicles to be allocated to other Luxembourg entities. These vehicles fall under the OECD’s definition of securitization entities. Additional updates clarify how the GloBE model rules apply to flow-through and hybrid entities. The amendments will apply retroactively to fiscal years starting on or after December 31, 2023. The bill now awaits review by the Council of State, with a request to bypass a second parliamentary vote, allowing direct approval by the Duke upon Council consent.
To learn more on the amendments, you can access the Bill by clicking here.