Luxembourg submits Public Country-by-Country Reporting Bill


In Brief

On 24 February 2023, a bill (Bill n° 8158) has been submitted to the parliament implementing the European Union (EU) directive regarding the Disclosure of Income Tax Information by Certain Undertakings and Branches (2021/2101) (the Public Country-by-Country Reporting (CbCR) Directive). 

EU Member states are required to transpose the content of the Public CbCR Directive in their domestic legislations by 22 June 2023. Consequently, based on the directive, the Public CbCR should take effect in Luxembourg for accounting periods beginning on or after 22 June 2024.

In scope of the Public CbCR are Multinational enterprises (MNEs) with a consolidated annual revenue of at least EUR 750 million for two consecutive years. MNEs falling in scope will be required to publicly disclose their CbCR. 

The Public CbCR will be an additional requirement for MNEs besides the existing CbCR reporting that is in place since 23 December 2016.

What are the requirements of the Public CbCR bill ?

Who is concerned? 
  • EU-based MNEs and non-EU-based MNEs doing business in the EU through a branch or subsidiary with total consolidated revenue of more than EUR 750 million in each of the last two consecutive financial years.

What to disclose ?
  • Among others, information on the amount of income, profit before tax, corporate tax payable and withholding tax on a per-country basis.

How to publish ? 
  • The report must be publicly disclosed in one of the EU official languages and deposited each year: 
    • On the website of the Ultimate Parent Entity (UPE) or the standalone undertaking; or
    • In the registre de commerce et des sociétés (Commercial and companies register), if available free of charge;
  • In line with the possibility offered by the Public CbCR Directive, Luxembourg has opted to allow companies to temporarily (up to five years) omit specific data from the declaration in cases where this would be particularly detrimental to the company's commercial position.

  • EU Banks already disclosing information within the scope of the CRD IV. 

Public CbCR – Additional requirements for Public CbCR

The Public CbCR is a separate filing requirement than the existing CbCR. We hereby summarise the main different requirements.

Main Characteristics

2016 CbCR regulation

Public CbCR (2024)

Type of disclosure

Luxembourg tax authorities

Website of the UPE or standalone undertaking

Reporting entity

Ultimate Parent

Ultimate EU Parent; or

Standalone EU entity;

Qualifying EU entities (in case of non-EU parented group)

Minimum threshold

EUR 750 M in previous fiscal year

EUR 750 M for two consecutive fiscal years

Revenues information

Separately for related and unrelated parties
(by jurisdiction)

Aggregated revenues
(by jurisdiction)


EUR 250,000

Liability for board members – penalty between EUR 500 to EUR 25,000

Public CbCR and Environmental, Social and Governance

As part of a broader consideration on tax strategy, tax transparency, and tax governance, Public CbCR is one of the first global legislative initiatives requiring MNEs to publicly disclose elements of their tax affairs to various stakeholders. MNEs should take the opportunity of Public CbCR to reflect on their tax strategy, review their tax governance and establish a public tax transparency policy as an element of their wider ESG strategy.


The Public CbCR is an additional filing obligation for MNEs. The disclosure of information to the public will be a new phase in the push for more transparency. However, interpretation of the information may be challenging as it is on an aggregated basis, so MNEs may have to consider how to best explain their disclosure to mitigate misinterpretations.

Contact us

Caroline Goemaere

Tax Partner, Transfer Pricing, PwC Luxembourg

Tel: +352 49 48 48 3002

Christophe Hillion

Tax Partner, Transfer Pricing, PwC Luxembourg

Tel: +352 49 48 48 2031

Pawel Wroblewski

Tax Partner, Transfer Pricing, PwC Luxembourg

Tel: +352 49 48 48 4541

Marc Rasch

Tax Partner, Transfer Pricing, PwC Luxembourg

Tel: +352 49 48 48 3712