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

The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Hani Ashkar, after more than 12 years leading PwC in the region, is set to be replaced by Laura Hinton
With the three-year anniversary of the PwC tax scandal approaching, it’s time to take stock of how tax agent regulation looks today
Rolling out the global minimum tax has increased complexity, according to Baker McKenzie; in other news, Donald Trump has announced a 25% tariff on countries doing business with Iran
Among those joining EY is PwC’s former international tax and transfer pricing head
The UK firm made the appointments as it seeks to recruit 160 new partners over the next two years
The network’s tax service line grew more than those for audit and assurance, advisory and legal services over the same period
The deal is a ‘real win’ for US-based multinationals and its announcement is a welcome relief, experts have told ITR
Tom Goldstein, who is now a blogger, is being represented by US law firm Munger, Tolles & Olson
In looking at the impact of taxation, money won't always be all there is to it
Gift this article