As of 1 January 2024, Liechtenstein implemented the global minimum taxation of the OECD/G20 Inclusive Framework on BEPS in accordance with the GloBE Model Rules. All domestic constituent entities (legal persons, trusts and partnerships) of a multinational enterprise group or a large domestic group are subject to the minimum taxation for tax years from 2024, provided that their Ultimate Parent Entity has annual revenue of at least EUR 750 million in its Consolidated Financial Statements (including deemed consolidation) in at least two of the four previous fiscal years.

An effective minimum tax level of 15 % is achieved by levying a Liechtenstein top-up tax (“Qualified Domestic Minimum Top-up Tax”; QDMTT) and an IIR top-up tax (“Income Inclusion Rule”). The constituent entities concerned must apply the provisions of the GloBE Act in addition to the Tax Act.

The tax return for the Liechtenstein and the IIR top-up tax must be submitted to the Fiscal Authority within 15 months after the financial year-end (18 months in the case of first-time application). The general due date for the 2024 tax year is June 30, 2026. The tax amount must be transferred to the following bank account within 30 days after the due date:

LI91 0880 0000 0219 9000 9             
Liechtensteinische Landesbank    
Payment reference:

•  «IIR, PEID, name of company» bzw
• «QDMTT, PEID, name of company»

The OECD/G20 standard also includes an automatic exchange of GloBE information under the GIR MCAA. Reporting entities (typically the Liechtenstein UPE) must register with the Fiscal Authority as a GIR reporting entity and submit GIR reports. GIR reports for the 2024 financial year must be submitted to the Fiscal Authority by 30 June 2026 at the latest.

You can find more information in the legal basis as well as in the auxiliary means. You can also obtain up-to-date information from the Newsletter of the Fiscal Authority.

Fiscal Authority
globe@llv.li