On 28 March 2023, a draft bill of law aiming at modernizing and simplifying the Luxembourg General Tax Act (“GTA”) was published (the “Bill”). The Bill provides for the implementation into Luxembourg law of BEPS Action 13, commonly known as Master File / Local File regulation.
Luxembourg Constituent Entities (“LCE”) of an MNE group, as defined in the Country-by-Country regulation will need to document their transfer pricing policy. LCE with a net turnover of at least EUR 100 million or a total balance sheet at closing date of at least EUR 400 million will need to file a Master File.
A Grand Ducal decree should provide for a list of information to be enclosed in the transfer pricing documentation.
If voted, the law should enter into force as from 1 January 2024.
