Corporate Tax 2026

LUXEMBOURG Law and Practice Contributed by: Romain Tiffon and Marie Bentley, ATOZ Tax Advisers

9.14 Offshore IP Provisions Luxembourg has not enacted any specific tax rules aimed at taxing offshore intellectual property used within its territory.

• no special tax on digital platforms operating from abroad. Luxembourg supports an OECD/Pillar One multilateral solution rather than unilateral measures. 9.13 Approach to Digital Services Taxation Luxembourg strongly rejects unilateral DSTs due to risks of fragmentation and double taxation. Luxem - bourg will implement Pillar One only when a multilat - eral treaty‑based solution is finalised.

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