Luxembourg Publishes List of Jurisdictions Eligible for Automatic Exchange of Pillar Two GloBE Information Returns
On 26 May 2026, the Luxembourg Government issued a Grand-Ducal Regulation identifying the jurisdictions that have concluded an eligible competent authority agreement with Luxembourg for the automatic exchange of specific sections of the Global anti-Base Erosion (GloBE) Information Return (GIR) under the OECD Pillar Two framework.
The publication of this list is an important development for multinational enterprise (MNE) groups subject to the Global Minimum Tax rules, as it provides greater certainty regarding both information exchange obligations and access to local filing relief in Luxembourg.
Why Is the List Important?
Under Luxembourg's Pillar Two legislation, a Luxembourg constituent entity may be exempt from filing a local GIR where the return is filed by the Ultimate Parent Entity (UPE) or another designated filing entity located in a jurisdiction included on the Luxembourg list.
The existence of an eligible exchange agreement ensures that the Luxembourg tax authorities can obtain the relevant GIR information through automatic exchange mechanisms, thereby reducing duplicate reporting obligations within the group.
Where local filing relief is claimed, the Luxembourg constituent entity must nevertheless notify the Luxembourg tax authorities of the identity and jurisdiction of the filing entity.
Jurisdictions Covered
The list includes:
All EU Member States, for which the exchange of information is facilitated through the EU administrative cooperation framework (DAC9); and
Certain non-EU jurisdictions that have signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information Returns (GIR MCAA) and completed the necessary OECD notification procedures to enable exchanges with Luxembourg.
The regulation generally applies to fiscal years beginning on or after 31 December 2023. Specific effective dates apply to certain jurisdictions, including:
Japan – fiscal years beginning on or after 1 April 2024
Hong Kong – fiscal years beginning on or after 1 January 2025
A Dynamic Framework
The Luxembourg authorities have indicated that the list will be updated as additional jurisdictions become eligible for automatic exchanges under the GIR MCAA framework. Importantly, future updates may apply by reference to the relevant reporting year rather than the publication date of the update.
Groups should therefore continue to monitor developments closely, as additional jurisdictions may become eligible for the exchange of 2024 reporting-year GIRs.
Practical Implications
With the Luxembourg GIR filing portal now operational, affected groups should review their Pillar Two reporting strategy and confirm whether local filing relief is available. Luxembourg entities intending to rely on an overseas filing should ensure that:
The filing jurisdiction appears on the Luxembourg list; and
Appropriate evidence of the GIR filing is maintained as part of the group's Pillar Two compliance documentation.
The publication of the list represents a significant operational step in the implementation of the Pillar Two reporting framework and provides welcome clarity for taxpayers seeking to coordinate GIR filing obligations across multiple jurisdictions.
