On 24 July 2025, the Luxembourg government released the draft law No. 8591 transposing the Directive (EU) 2025/872, also called DAC9, amending the directive on administrative cooperation in the field of taxation (DAC), for the ninth time, to facilitate compliance with the filing obligations of companies under the 2022 Pillar Two directive which aims to ensure a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the EU.
The draft law introduces targeted amendments to the existing Luxembourg Pillar Two law with a focus on easing the compliance burden and clarifying the treatment of deferred taxes for Pillar Two purposes. In line with DAC9, Luxembourg also establishes the foundation for a system for tax authorities to exchange Pillar Two information with each other.
In this Alert, our Tax Partner, Andreas Medler, outlines the key elements of this draft law and their implications for Luxembourg companies.