The Luxembourg Parliament on 13 December 2016 passed legislation implementing country- by-country (CbC) reporting requirements for Luxembourg entities that are part of a Multinational Enterprise Group (MNE Group). The new CbC reporting legislation transposes into Luxembourg law part of the three-tiered standardised approach to transfer pricing documentation introduced in Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.
The Luxembourg CbC obligations require Luxembourg ultimate parent entities controlling an MNE group whose total consolidated group revenue (chiffre d’affaires total consolidé) exceeds EUR 750 million, to file CbC reports with the Luxembourg tax authorities. Other Luxembourg companies that are members of MNE groups may also have obligations to file CbC reports in Luxembourg. Both Luxembourg MNE group parents, and other Luxembourg companies that are members of MNE groups must also comply with notification requirements that have deadlines that are potentially imminent.
