Pillar Two – Minimum effective taxation

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Summary:

The registration and filing procedures required under the Pillar Two Law must be completed online on MyGuichet.lu.

Go to online services and forms

The rules on minimum effective taxation are defined in the Law of 22 December 2023 (as amended) on minimum effective taxation for multinational enterprise groups and large-scale domestic groups ('Pillar Two Law').

The procedures for registering and for filing top-up tax-information returns and top-up tax returns must be completed with the Luxembourg Inland Revenue (Administration des contributions directes - ACD) on MyGuichet.lu.

Who is concerned

The persons concerned (hereinafter referred to as 'entity concerned') depend on the procedure.

Constituent entities, joint ventures and entities affiliated with a joint venture, as referred to below, should be understood as those falling within the scope of the Pillar Two Law.

The location of such an entity concerned is that determined in accordance with said Law.

Registering an entity

Registering with the ACD is a required for:

  • constituent entities located in Luxembourg;
  • joint ventures located in Luxembourg;
  • entities affiliated with a joint venture located in Luxembourg.

Filings

Top-up tax-information returns must be filed by all constituent entities located in Luxembourg.

Top-up tax returns must be filed by:

  • all constituent entities;
  • all joint ventures;
  • all entities affiliated with a joint venture;

that are located in Luxembourg and are subject to, or are taxed:

  • under the Income Inclusion Rule (IIR);
  • under the Undertaxed Profit Rule (UTPR); or
  • under the national top-up tax regime.

Prerequisites

Registration

In order to register, the entity concerned must have a Luxembourg tax identification number (numéro d’identification fiscale luxembourgeois - NIF). This is an 11-digit number that is also referred to as a 'matricule' or 'numéro d’identification personnelle'.

If the entity concerned does not have a Luxembourg NIF, it may apply for one prior to registering by contacting the ACD's Office for Withholding Tax on Interest by telephone on (+352) 247 524 61, or by email at gir@co.etat.lu.

Deadlines

The following provisions notwithstanding, the first deadline for completing and filing these procedures is 30 June 2026.

Registering an entity concerned

The entity concerned must register with the ACD on MyGuichet.lu:

  • within no more than 15 months of the last day of the applicable tax year during which the multinational enterprise group, or the large-scale domestic group to which it belongs, falls within the scope of the Pillar Two Law, or during which it becomes part of a multinational enterprise group or large-scale domestic group, as referred to in the Pillar Two Law; or
  • within no more than 18 months of the last day of the applicable tax year during which the multinational enterprise group, or the large-scale domestic group to which it belongs, falls within the scope of the Pillar Two Law, or during which it becomes part of a multinational enterprise group or large-scale domestic group, as referred to in the Pillar Two Law.

The entity concerned must notify the ACD of any changes in the information relating to registration within no more than 15 months of the last day of the applicable tax year during which said changes occurred.

The entity concerned must deregister with the ACD on MyGuichet.lu within no more than 15 months of the last day of the applicable tax year during which the multinational enterprise group, or the large-scale domestic group to which it belongs, ceased to fall within the scope of the Pillar Two Law, or during which it ceases to be a concerned entity located in Luxembourg within said group.

Filings

Top-up tax-information returns must be filed with the ACD on MyGuichet.lu:

  • within no more than 15 months of the last day of the applicable tax year; or
  • within no more than 18 months – unless granted a derogation – of the last day of the first applicable tax year during which the multinational enterprise group, or the large-scale domestic group to which the entity concerned belongs, falls within the scope of the Pillar Two Law.

The entity concerned is required to file a top-up tax return with the ACD on MyGuichet.lu:

  • within no more than 15 months of the last day of the tax year; or
  • within no more than 18 months – unless granted a derogation – of the last day of the first applicable tax year during which the multinational enterprise group, or the large-scale domestic group to which it belongs, falls within the scope of the Pillar Two Law.

How to proceed

Registering an entity concerned

Registering with the ACD must be carried out online on MyGuichet.lu.

This procedure requires authentication using a LuxTrust product or an electronic identity card (eID) (see 'Online services and forms').

After commencing the procedure, entities simply need to follow the instructions provided by the electronic assistant in order to complete the registration process. The electronic assistant can also be pre-populated using a file in XML format.

Any changes that occur after registration must be reported.

Correcting information, updating a registration, or deregistering can be carried out using the 'Pillar Two – Registration' procedure.

Filings

The following must be filed online on MyGuichet.lu:

  • top-up tax-information returns;
  • top-up tax returns.

This procedure requires authentication using a LuxTrust product or an electronic identity card (eID) (see 'Online services and forms').

The top-up tax-information return must be filed by submitting a file in XML format on the MyGuichet.lu platform.

The return must be filed by a constituent entity located in Luxembourg.

It is exempted from this obligation if the return has been filed by a local entity appointed to act on behalf of the constituent entity. However, the appointed local entity must be reported at the time of registration.

Furthermore, it is exempted from this obligation, subject to certain conditions, if the declaration was filed by:

  • the ultimate parent entity located in a different jurisdiction; or
  • the appointed filing entity located in a different jurisdiction.

The local entity appointed to act on its behalf or, failing that, the constituent entity located in Luxembourg, is required to notify the ACD of the following:

  • the identity of the entity filing the top-up tax-information return (GIR); and
  • the jurisdiction in which the filing entity is located.

This notification must be carried out using the 'Pillar Two – Registration' procedure (see 'Online services and forms').

The return must be filed by the entity concerned.

This procedure requires authentication using a LuxTrust product or an electronic identity card (eID) (see 'Online services and forms').

After commencing the procedure, entities simply need to follow the instructions provided by the electronic assistant in order to complete the filing. The electronic assistant can also be pre-populated using a file in XML format.

Penalties

Registering an entity concerned

Any constituent entity, joint venture, or entity affiliated with a joint venture that is located in Luxembourg and fails to register, or fails to inform the ACD of any changes, or fails to deregister by the statutory deadline is liable to a EUR 5,000 fine, which can also be levied if the information provided is found to be incomplete or inaccurate.

A constituent entity located in Luxembourg, or an appointed local entity that fails to notify the ACD by the statutory deadline, or which sends a notification that is incomplete or inaccurate, is liable to a EUR 5,000 fine. Notification in this context refers to the act of notifying the ACD of the identity of the entity filing the top-up tax-information return and the jurisdiction in which it is located.

Top-up tax-information returns

A constituent entity located in Luxembourg, or an appointed local entity that fails to file the top-up tax-information return by the statutory deadline, or which files a return that is incomplete or inaccurate, is liable to a fine of up to EUR 250,000 (unless an exemption applies). The applicable fine can be as high as EUR 300,000 depending on the circumstances.

Top-up tax returns

If the entity fails to file the top-up tax return, or if the return is incomplete or inaccurate, the ACD's board of assessment Sociétés Diekirch will issue a tax assessment specifying the amount of the shortfall.

Online services and forms

Online services

Pilier 2 - Enregistrement

Déclaration d’information pour l’impôt complémentaire

Déclaration concernant l’impôt complémentaire

Who to contact

Contact Centre - Luxembourg Inland Revenue (ACD)

Address:
33, rue de Gasperich L-5826 Hesperange Luxembourg

Contact form

To be allocated a Luxembourg tax identification number (NIF), please contact the ACD's Office for Withholding Tax on Interest by telephone on (+352) 247 524 61, or by email at gir@co.etat.lu.

Related procedures and links

Links

Further information

Legal references

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