For its final enactment and entry into force, the GloBE Tax Law first needs to be approved and sanctioned by the Reigning Prince of Liechtenstein.
It’s expected that approval should follow in due course. The GloBE Tax Law foresees introducing a Qualified Domestic Minimum Tax ‘QDMTT’, an Income Inclusion Rule ‘IIR’ and the Under Tax Profit Rules ‘UTPR’.
The GloBE Law shall generally become effective for tax years starting on or after 1 January 2024. But the GloBE Law was adjusted by the parliament so that the government, by means of an ordinance, can still decide to make the GloBE Law effective only as of 1 January 2025. The effective date of the UTPR is to be defined separately through a second ordinance and can enter into force on 1 January 2025 at the earliest. When deciding on the effective date of the GloBE Tax Law overall as well as the UTPR, the government has to consider the status of implementation of the OECD model rules on a global level. With such an adjustment, the Liechtenstein parliament has set the legal basis for the introduction of GloBE, but still kept flexibility and discretion for the government to defer the implementation for one year, depending on what other important countries around the globe decide to do.
Generally, the Liechtenstein GloBE Tax Law follows the OECD model rules. Beside multinational enterprises with gross revenue of more than EUR750m, in analogy to the EU Council Directive, pure domestic Liechtenstein groups exceeding the revenue threshold will also fall under the GloBE Tax Law. Not only do corporate vehicles fall under the definition of multinational enterprises, but also trusts, foundations and establishments. This means that any Liechtenstein corporate or legal vehicle of any form should assess whether it falls under the new GloBE Tax Law.
For further details, visit the PwC OECD Pillar Two Country Tracker or contact our PwC Liechtenstein GloBE experts.
