Minimum Taxation (GloBE)
As of January 1, 2024, Liechtenstein has implemented the global minimum tax under the OECD/G20 Inclusive Framework on BEPS in accordance with the GloBE Model Rules. Domestic business entities (legal entities, trusts, and partnerships) belonging to a multinational corporate group or a large domestic group are also subject to the minimum tax under the GloBE Model Rules for tax years beginning in 2024, provided that their ultimate parent company has achieved consolidated annual revenue of at least EUR 750 million in its consolidated financial statements (including deemed consolidation) in at least two of the four preceding fiscal years.
An effective minimum tax rate of 15% is achieved through the imposition of a Liechtenstein supplemental tax (“Qualified Domestic Minimum Top-up Tax”; QDMTT) as well as an IIR supplemental tax (“Income Inclusion Rule”). The affected business units must apply the provisions of the GloBE Act in addition to the Tax Act.
The tax return for the Liechtenstein and IIR supplemental taxes must be submitted to the Fiscal Authority no later than 15 months after the end of the fiscal year (18 months for 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 of the due date:
LI91 0880 0000 0219 9000 9
Liechtensteinische Landesbank
Payment reference:
- “IIR, PEID, Company Name” or
- “QDMTT, PEID, Company Name”
The OECD/G20 standard also includes an automatic exchange of GloBE information in accordance with the GIR MCAA. Reporting business 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 fiscal year must be submitted to the Fiscal Authority by June 30, 2026, at the latest.
Further information can be found in the relevant legislation and guidance materials. You can also obtain up-to-date information through the Fiscal Authority’snewsletter.
More Information
GIR reporting entities can register via the Liechtenstein International Data Exchange Service Portal (LIDES Portal) and submit GIR reports to the Fiscal Authority.
Instructions for Using the LIDES Portal
If you have any questions about the LIDES Portal, please feel free to contact the Fiscal Authority (lides@llv.li).
To use the LIDES Portal, you must have access to the “eID.li” and “eVertretung” basic services. Information on obtaining and using eID.li can be found ateid.li, and if you have any questions about eID.li, please feel free to contact the Migration and Passport Office (info.apa@llv.li). Information on eVertretung and service authorizations can be found on the Office of Justice’s website (link), and if you have any questions, please feel free to contact the Office of Justice (evertretung.aju@llv.li).
GIR XML Schema
Additional XML Specifications from the Fiscal Authority
GloBE Information Return (GIR) (available in English only)
Instructions for the GIR Allocation Approach According to the GIR MCAA
Safe Harbor and Leniency Programs (available in English only)
Implementation Handbook (available in English only)
Side-by-Side Package (available in English only)
Central Record for purposes of the Global Minimum Tax (available in English only)
Contact
Fiscal Authorityglobe@llv.li