On March 29, 2023 the Government of Liechtenstein announced that it opened a consultation on draft legislation to implement a global minimum taxation of large multinationals and large Liechtenstein domestic groups (Pillar 2 of the Two-Pillar solution). The consultation period ends on June 2, 2023. The consultation report and the law proposal are to be discussed in parliament in the beginning of September 2023.

The present draft regaqrds the national implementation of the global minimum taxation. The implementation should be targeted on business units of multinational groups of companies that are covered by the GloBE model regulations of the OECD. For this purpose, a law on the minimum taxation of large groups of companies (GloBE law) is to be created and the law on state and municipal taxes (SteG) is to be amended. Due to Liechtenstein's membership in the EEA, large domestic groups must also be included in the scope, analogous to the implementation in the EU, even although this is not provided for in the GloBE model regulations of the OECD.

The implementation provides for the introduction of a Liechtenstein supplementary tax in the form of an "Income Inclusion Rule" as well as a "Qualified Domestic Minimum Top-up Tax" and an "Undertaxed Payments Rule".

The consultation document containing the draft legislation to implement a global minimum taxation of large multinationals and large Liechtenstein domestic groups can be found here.

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