As such, Liechtenstein groups and companies within the threshold of global minimum tax will be subject to the Qualified Domestic Minimum Tax ‘QDMTT’ and Income Inclusion Rule ‘IIR’ of 15 % for tax years starting on or after 1 January 2024.
The effective date of the UTPR is to be defined separately through a second ordinance and can only enter into force on 1 January 2025 at the earliest. As such, it remains open when UTPR may be introduced.
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 starting 1 January 2024.
The GloBE Tax Law requires groups to file an additional tax return for QDMTT and IIR in Liechtenstein. The filing due date for the first tax return is 30 June 2026. While the required filing data points are defined (see PwC Pillar Two Data Input Catalog), the respective Liechtenstein returns are still to be published.
PwC has a global network and tools available to support with GloBE tax returns, data gathering and process organisation.
For further details, visit the PwC OECD Pillar Two Country Tracker or contact our PwC Liechtenstein GloBE experts.
