Luxembourg Implementing Pillar 2 Side-by-Side Package

The Luxembourg parliament is considering a draft law submitted on 17 July 2026 that amends the Law of 22 December 2023 on the minimum effective taxation of multinational enterprise groups and large national groups. The amendments provide for the implementation of the Pillar 2 Side-by-Side package announced by the OECD in January 2026, including:

• The Qualified Side-by-Side (SbS) Safe Harbour, which sets the top-up tax under both the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule…