On 18 January 2023, the Luxembourg Tax Authority updated the frequently asked questions (FAQs) on country-by-country (CbC) reporting according to the guidance issued by the OECD in October 2022. The latest updates include the following clarifications:
- When an investment fund has sub-funds or compartments, only the main fund (also known as the umbrella fund) is considered a constituent entity of the MNE (multinational enterprise) group. There is no requirement to file separate notifications for each sub-fund or compartment or to include their identities in declarations.
- The reporting entity of an MNE Group with a short accounting period beginning on or after 1 January 2016 and ending before 31 December 2016 may file the mandatory CbC report within the time limit provided for MNE groups whose fiscal year ends on 31 December 2016.
- For the purposes of applying the threshold of EUR 750 million when the previous accounting period of the ultimate parent entity covered a duration of less than 12 months, the total consolidated turnover should be adjusted to the amount that would correspond to a 12-month accounting period.
