Tax & Accounting Blog

Luxembourg Publishes Extended Notifications for Country-by-Country Reporting

BEPS, Blog, Checkpoint, ONESOURCE, Transfer Pricing December 30, 2016

On December 27, 2016, Luxembourg published a newsletter, saying that the government has implemented country-by-country (CbC) reporting and the mandatory automatic exchange of CbC information. See BEPS Action 13.

On December 13, 2016, the Luxembourg Parliament adopted Law No. 7031, implementing CbC reporting and the mandatory automatic exchange of CbC information. Annual CbC reporting is required for multinational groups with total consolidated revenue (as reflected in its consolidated financial statements) of at least €750,000,000 during the fiscal year immediately preceding the reportable fiscal year. The first reporting fiscal year of the group begins on January 1, 2016 or later.

Before submission of a CbC report, taxpayers must first submit a notification to the Luxembourg Inland Revenue, via the online assistant, indicating the identity and fiscal residence of the business entity that will submit the report on behalf of the multinational group. Each constituent entity of a multinational group that is established in Luxembourg for tax purposes is required to submit the notification. Constituent entities do not need to submit a notification if the group has, with respect to any fiscal year, a total consolidated turnover of less than €750,000,000, or an amount in local currency approximately equivalent as of January 2015, during the fiscal year immediately preceding the reporting fiscal year.

Notifications must be submitted by the last day of the reporting fiscal year of the group. The deadline for the exchange of notifications for the 2016 fiscal year has been extended to March 31, 2017

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