The initial effects of Pillar 2 are beginning to be reflected in the figures. In a response to a parliamentary question from the MP 
Pillar 2 is the international tax reform spearheaded by the OECD, which has since been transposed into European and Luxembourg law. Since 1is From January 2025, multinational groups and large domestic groups with a consolidated turnover of at least €750 million will be subject to a minimum effective tax rate of 15 per cent. If this threshold is not met in a particular jurisdiction, a supplementary tax is payable to bring the tax liability up to this level.
By mid-July 2026, 8,695 entities had registered in Luxembourg under this legislation. At the same time, 231 entities had filed an information return for the supplementary tax. The Minister points out, however, that these two figures are not directly comparable. A single return may cover several entities within a group, whilst certain companies are exempt from filing their return in Luxembourg if this is done by another entity within the group.
Indeed, use of the international centralised filing mechanism is already widespread. 3,643 entities have indicated that their returns will be filed in another jurisdiction via the OECD’s Central Filing and Exchange Framework, before being automatically forwarded to Luxembourg.
Several missing answers
From a budgetary perspective, the initial figures reported are far from insignificant. By mid-July, returns filed with the Direct Tax Authority showed €59.8 million in supplementary national tax and €165.1 million under the income inclusion rule (RIR), totalling nearly €225 million. The Minister emphasises, however, that these figures are provisional and may be revised following tax audits if certain returns prove to be inaccurate or incomplete.
However, the government was unable to answer several questions raised by the Socialist MP regarding the average effective tax rate or the number of entities taxed at less than 5 per cent, 10 per cent or 15 per cent. Gilles Roth explains that Pillar 2 does not calculate a tax rate for each individual company, but rather on a jurisdiction-by-jurisdiction basis and at the level of each multinational group. The indicators requested therefore do not correspond to the method of calculation provided for by law.
Above all, these figures represent the first tangible results of a reform that is gradually reshaping Luxembourg’s tax system. In September 2025, a study by the Chamber of Deputies’ scientific unit had already concluded that the entry into force of Pillar 2 marked the transition to ‘post-tax competitiveness’. After years in which Luxembourg had been criticised for the gap between its statutory tax rate and the rate actually paid by certain multinationals, the introduction of a global minimum rate of 15 per cent automatically reduces the appeal of such discrepancies. The study concluded that the country’s attractiveness will now have to rely more heavily on other strengths, such as political stability, legal certainty, a skilled workforce, infrastructure and innovation.
