Luxembourg’s Grand-Ducal Regulation of 26 May 2026 sets out the jurisdictions with which it will automatically exchange GloBE Information Returns under the global minimum tax framework (impôt complémentaire), specifying different effective dates for qualifying competent authority agreements from fiscal years starting on or after 31 December 2023, 1 April 2024, and 1 January 2025.
Luxembourg has published the Grand-Ducal Regulation of 26 May 2026 in the Official Gazette, setting out the list of jurisdictions with which it will automatically exchange information from GloBE Information Returns (GIRs) in relation to the global minimum tax framework (referred to in the text as the “impôt complémentaire”).
The regulation, issued by Grand Duke Guillaume and reported by Gilles Roth, Minister of Finances, is based on the modified law of 22 December 2023 concerning the effective minimum taxation for large-scale multinational and national groups, and the law of 19 December 2025 on the automatic exchange of information declarations for the complementary tax.
It establishes which jurisdictions are regarded as having entered into a qualifying competent authority agreement with Luxembourg for different reportable fiscal years, and therefore determines the scope of automatic exchange of GIR information.
For fiscal years starting on or after 31 December 2023, the regulation lists 34 jurisdictions with effective agreements, including Germany, France, Italy, Spain, the Netherlands, Belgium, Ireland, Portugal, the United Kingdom, Canada, Australia, Japan, South Korea, and several other EU and OECD partner jurisdictions.
For fiscal years starting on or after 1 April 2024, Japan is included as having a taking-effect agreement. For fiscal years starting on or after 1 January 2025, Hong Kong (China) is added to the list of jurisdictions with an effective agreement.
The Grand-Ducal Regulation is retroactively effective as of 1 January 2026, and the Minister of Finances is responsible for its execution and publication in the Journal Officiel.
