Wednesday, 19 October 2016

Luxembourg Government proposes new country-by-country reporting obligations

The Luxembourg Government on August 2, 2016, lodged a draft law introducing country-by-country (CbC) reporting obligations for Luxembourg entities that are part of a Multinational Enterprise Group (MNE Group). CbC obligations constitute one element of the new three-tiered standardized approach to transfer pricing documentation introduced by Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.

The draft law would enact Council Directive (EU) 2016/881 of May 25, 2016, regarding mandatory, automatic exchange of information in the field of taxation in Luxembourg law. If the law is adopted, Luxembourg CbC obligations will require Luxembourg ultimate parent entities, if part of an MNE Group whose total consolidated group revenue (chiffre d'affaires total consolidé) exceeds EUR 750 million, to file a CbC report with the Luxembourg tax authorities.

Source & more info: PwC