Luxembourg accepts OECD Amount B for distribution activities

Country reference

• Country: Luxembourg (planned expansion country)
• Authorities: Administration des contributions directes (ACD); Ministry of Finance
• Topic: Simplified transfer pricing approach for marketing and distribution (Amount B)
• Key date: Circular of 13 April 2026; financial years from 1 January 2025
• Law: Circular L.I.R. No. 56/2 – 56bis/2

What the circular says

The ACD aligns with the OECD’s Amount B framework. Where a covered jurisdiction applies Amount B to baseline wholesale distribution by a local distributor, Luxembourg will not adjust the price, will grant a corresponding adjustment, or will resolve double tax through a mutual agreement procedure.

Conditions

• The other country is a covered jurisdiction as defined by the OECD.
• A double tax treaty is in force between Luxembourg and that country.
• That country has chosen to apply Amount B.
• The tested distributor is in the covered jurisdiction.

Limits

• It covers baseline wholesale distribution only, not services, intangibles or commodities.
• Amount B must be disclosed in the Luxembourg corporate tax return and substantiated.
• It cannot support pricing for out-of-scope transactions.

Who is affected

• Luxembourg principal or trading companies selling through related distributors in countries that apply Amount B.
• Groups using Luxembourg as an IP or supply hub for emerging markets.

What to do now

• List related distributors and check which countries apply Amount B.
• Confirm treaty coverage with each country.
• Add Amount B disclosures to 2025 tax returns where relevant.

Our take

Luxembourg does not impose Amount B but avoids double tax where others do. That helps groups selling into markets that adopt the simplified approach.