Luxembourg releases paper on tax transparency amid “Lux leaks” controversy

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Luxembourg releases paper on tax transparency amid “Lux leaks” controversy

On December 10 the Luxembourg Ministry of Finance released proposals relating to tax transparency and advance rulings. This move comes as no surprise in the light of the recent “Lux leaks” scandal and appears to be a strategic attempt at advertising Luxembourg’s willingness to fight tax evasion.

The position paper outlines that:

· A specific provision would be added to the tax law regarding transfer pricing documentation;

· From 2015, the tax administration would provide an annual report of all tax ruling issues for the year;

· The income tax law of Luxembourg would be modified to explicitly state that profit of related-party enterprises would be determined under an arm’s-length standard and then taxed according to OECD principles; and

· Requests for corporate tax rulings, filed with the tax office, would have to be submitted to the newly established supervisory commission (commission des decisions anticipées) which is authorised to issue a binding opinion on which the tax office’s advance ruling would be based.

According to the paper, these legislative changes, which are already considered administrative practice by the Luxembourg tax office, would be codified into law.

Perfect timing

There is no denying that the proposals were released in response to the “Lux leaks” scandal.

“The form and timing of the release was expected in the context of the recent “Lux leaks”. It is a move to clarify Luxembourg’s position that there should be more transparency around rulings,” said Keith O’Donnell of Atoz.

The proposals will come as no surprise to taxpayers who were already expecting significant changes to improve tax transparency in the country. The release of the proposals appears to be more of a publicity stunt to reassure the international tax community that Luxembourg is fully committed to tackling the fight against base erosion and profit shifting.

more across site & shared bottom lb ros

More from across our site

Awards
Leading firms and individuals gathered in Dubai to celebrate standout legal, dealmaking and tax work across the region
Tax authorities want more revenue, have better tools to find it and are increasingly willing to fight for it
Audifina, the sixth-largest firm of its kind in Lithuania, will bring a 90-strong team with offices in Vilnius and Kaunas to RSM’s international platform
As global capability centres use AI to deliver services, MNEs face a fresh wave of PE and TP exposure that their existing playbooks weren't built for
The deal for Comtax hands Ryan immediate scale in Brazil, with a near-70-strong team serving clients from São Paulo
The arrivals of Julio Castro and Adam Blakemore mean the firm has added six tax partners to its global practice since the start of 2025
Tax authorities have gained unprecedented transparency through CbCR, but a new study suggests they may not be looking in the right places
The future chief tax officer will be judged not only on compliance, but on their ability to harness data, technology and AI to support strategic decision-making
More than 200 tier promotions reshaped this year's European rankings as several international firms strengthened their positions in key tax markets
Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general
Gift this article