Luxembourg recently transposed these new rules into domestic law (Law of 26 July 2023). As the first reporting should take place by 30 April 2024, PSPs that are established in Luxembourg or provide payment services that are in the scope of the reporting in Luxembourg should assess their reporting obligations and ensure that the proper compliance processes/tools are in place.

Considering that the implementation of these new rules has raised a number of practical challenges for PSPs and the national tax authorities across the EU, the EU Commission recently published on its official website a set of Frequently Asked Questions (“FAQs“). Although this document undoubtedly provides useful guidance on the interpretation of CESOP rules, it cannot address all possible cases and a specific assessment is still required.