We have already enjoyed early spring days, so it’s time for our first 2026 ATOZ Insights.
On 6 January 2026, the Luxembourg tax authorities launched online procedures via MyGuichet.lu for Pillar Two compliance. We outline the key obligations for Luxembourg constituent entities, including mandatory registration, GloBE Information Return filings and Top‑up Tax Return procedures.
We also analyse the permanent establishment risks arising from cross‑border remote work for Luxembourg businesses, focusing initially on the OECD’s 2025 Commentaries regarding the assessment of a fixed place of business and subsequently on the dependent agent rules.
We then delve into the evolving concept of beneficial ownership, analysing its key role in accessing treaty and EU directive benefits, as well as recent case law trends emphasising substance, control and economic reality.
We also explore Luxembourg’s recent implementation of DAC8, which significantly expands the scope of tax transparency and automatic exchange of information, notably by introducing new reporting obligations for crypto-asset service providers and updating existing DAC regimes.
For VAT, we analyse a new Luxembourg District Court judgement on the application of administrative VAT penalties, even absent fraudulent intent and outline its implications for taxpayers.
Rounding off our Luxembourg coverage, we turn to legislative updates and take a deep dive into a new draft law introducing deferred payment of minimum share capital for SARLs, a reform aimed at modernising Luxembourg’s corporate framework.
From the Middle East, we analyse the UAE Federal Tax Authority’s first comprehensive Corporate Tax Guide on Advance Pricing Agreements. The guide establishes a formal framework for obtaining prospective transfer pricing certainty, with the aim of reducing disputes and preventing double taxation.
Read our full April 2026 ATOZ Insights below!