Pillar Two and Luxembourg’s CFC Tax Regime: A Roadmap to Tax Liability and Compliance

In this article, the author examines the OECD’s Pillar Two Global minimum tax framework and its impact on Luxembourg’s CFC rules, with a focus on alignment with international tax standards, including the global intangible low-taxed income (GILTI) regime and EU law. The article also highlights the tax adjustments Luxembourg may need to implement to align its regime with the OECD’s standards, stressing the importance of compliance to maintain Luxembourg’s competitiveness in the evolving global tax landscape.