Two Hundred Twenty-Five Million

The first numbers are in. Luxembourg's Pillar 2 global minimum tax regime, which came into force on January 1, 2025, has produced its first concrete figures. By mid-July 2026, 8'695 entities had registered under the legislation. 231 had filed information returns. And the total declared across those returns amounts to roughly 225 million euros[1].

That number, 225 million, is the first tangible evidence of a reform that has been debated, negotiated, and feared for years. It is also provisional. The Minister of Finance emphasized that the figures may be revised following tax audits if certain returns prove inaccurate or incomplete. But provisional or not, this is real money, declared by real companies, under a real law.

The breakdown is worth noting. Of the 225 million, 59.8 million comes from the supplementary national tax and 165.1 million from the income inclusion rule, which is the mechanism that lets a parent company's home country top up the tax on foreign subsidiaries paying below 15%. Together, these two streams make up the backbone of the OECD's Pillar 2 framework[2].

One detail stands out. Of the 8'695 registered entities, 3'643 have indicated their returns will be filed in another jurisdiction through the OECD's Central Filing and Exchange Framework. That means roughly 42% of registered entities are not filing directly in Luxembourg. Their data gets forwarded automatically from another country. This is the international plumbing of the global tax system working as designed, but it also means Luxembourg's own filing numbers undercount the actual scope of the reform.

The government could not answer several questions from the opposition MP who asked them. How many entities are taxed at less than 5%? What is the average effective tax rate? The Minister explained that Pillar 2 does not calculate a tax rate per company. It calculates on a jurisdiction-by-jurisdiction basis, at the level of each multinational group. The indicators requested simply do not match the method of calculation the law requires. This is either a genuine technical limitation or a convenient excuse. Possibly both.

What this means for Luxembourg is bigger than 225 million euros. A study by the Chamber of Deputies' scientific unit in September 2025 called this the transition to "post-tax competitiveness." For years, Luxembourg was criticized for the gap between its statutory tax rate and the rate actually paid by certain multinationals. That gap is what Pillar 2 was designed to close. A global minimum of 15% means that no matter where a company operates, it pays at least that rate. The appeal of a low-tax jurisdiction, by definition, shrinks[3].

The country now has to compete on other things. Political stability. Legal certainty. A skilled workforce. Infrastructure. Innovation. The things every country says it has, and only some actually do. The tax advantage that made Luxembourg an obvious choice for certain corporate structures is not gone, but it is no longer the deciding factor it once was.

225 million euros is a lot of money. But the bigger number is the one we do not have yet: the long-term impact on where multinational groups choose to locate, and whether Luxembourg's other strengths are enough to keep them here. The first returns are in. The real test starts now.