Luxembourg has published the Grand-Ducal Regulation of 22 January 2021 in the Official Gazette amending the list of jurisdictions with which the Luxembourg Tax Authorities will exchange Country-by-Country ("CbC") reports.
Accordingly, as from 1 January 2018, Andorra, Monaco, Seychelles and Panama are included on the list of exchanging countries.
Therefore, MNE Groups that have an Ultimate Parent entity in one of these three jurisdictions would need to (i) either designate a reporting entity in a listed jurisdiction or in Luxembourg (called "Surrogate Parent") or (ii) submit a local CbC report in Luxembourg via its Luxembourg subsidiaries.
For more information on CbC reporting, please check our previous newsletters of 5 April 2017
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