Executive summary

The Luxembourg Government, on 26 May 2026, released the list of jurisdictions that concluded an eligible competent authority agreement with Luxembourg for the purposes of the automatic exchange of specific sections of the Global anti-Base Erosion (GloBE) information return (GIR).

The existence of an eligible competent authority agreement is a central element of the Pillar Two information return mechanism, determining whether GIR information filed in Luxembourg or abroad can be obtained through automatic exchange.

Effect on exchange of information

The list contains the jurisdictions that are considered to have concluded an eligible competent authority agreement with Luxembourg for a given reportable fiscal year. These agreements are a key element of Pillar Two compliance, as they determine both:

• From which jurisdictions Luxembourg may receive (relevant sections) of GIRs filed in another jurisdiction via automatic exchange
• To which jurisdictions Luxembourg must transmit, in accordance with the dissemination approach, relevant sections of GIRS filed in Luxembourg

Effect on local filing obligations

Under the Pillar Two Law,² a Luxembourg constituent entity is exempt from filing a GIR in Luxembourg if the return is filed by the ultimate parent entity or a designated filing entity of the same group in a jurisdiction included on the list.³

The regulation therefore plays a critical operational role, as it identifies the jurisdictions for which Luxembourg tax authorities are expected to obtain GIR data via automatic exchange (which is critical for the local filing exemption).

If this exemption applies, the Luxembourg constituent entity (or the Luxembourg designated filing entity) must provide the Luxembourg tax authorities with the identity of the filing entity and the jurisdiction in which that entity is located.

Jurisdictions included in the list

The following jurisdictions are considered to have concluded an eligible competent authority agreement with Luxembourg:

• All EU Member States, for which the EU Directive on Administrative Cooperation (DAC9)⁴ constitutes such an agreement
• Non-EU jurisdictions that have signed the GIR MCAA and have deposited the relevant notifications with the Organisation for Economic Co-operation and Development (OECD) Secretariat enabling exchanges with Luxembourg⁵

Dynamic nature of the list

As additional jurisdictions sign the GIR MCAA and provide required notification, it is expected that the list will be updated. Groups should therefore closely monitor updates to the list. Changes are expected to apply by reference to the relevant reporting year (i.e., not just from the date an update is published).

Effect

For all of the jurisdictions listed, the agreement applies to fiscal years beginning on 31 December 2023 or later, with a specific rule for (1) Japan, which is included for fiscal years beginning on 1 April 2024 or later, and (2) Hong Kong, which is included for fiscal years beginning on 1 January 2025 or later.

Next steps and implications

The list provides clarity regarding the jurisdictions with which Luxembourg will automatically exchange the relevant sections of the GIR for a given reportable fiscal year, allowing taxpayers to determine the appropriate GIR filing jurisdiction(s). As the Luxembourg GIR filing portal is now open and operational, groups may already opt to file their GIR in Luxembourg and ensure timely compliance with filing requirements.

Taxpayers should monitor updates to the list, which are expected to be effective by reporting year, so that additional jurisdictions in respect of which reporting-year-2024 GIRs can be exchanged may yet be added.

A Luxembourg entity that intends to rely on local filing relief will have to include the GIR filing location in its registration. Evidence of filing of the GIR, whether in Luxembourg or abroad, should be retained in the group's Pillar Two compliance file.