On 22 March 2019, a new Grand-Ducal Decree amended the Decree of 13 February 2018 concerning the application of Article 4, paragraph 2 of the Law of 23 December 2016 regarding country by country reporting. The new Decree updates the jurisdictions that are subject to reporting and the fiscal year when such reporting will apply.
Country by country reporting has been implemented by Council Directive (EU) 206/881 of 25 May 2016 (the Directive) on the mandatory automatic exchange of information in the field of taxation.
The Directive was transposed in Luxembourg by the Law of 23 December 2016 (the Law).
The Law requires each “parent entity” of a group of multinational companies, which is a resident for tax purposes in Luxembourg (or any other reporting entity) to file, on an annual basis, a country-by-country report for each tax year with the Luxembourg tax authorities (Administration des contributions directes).
The new Grand-Ducal Decree has added:
- Hong-Kong, and
- Mauritius Island
to the list of reporting jurisdictions.
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