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During its meeting of July 11, 2023 the Government of Liechtenstein approved that the draft law to implement the minimum taxation of large corporate groups (GloBE law) and the accompanying Explanatory Memorandum were sent to the Liechtenstein Parliament for approval. The provisions of Pillar 2 are intended to ensure that multinational corporate groups with a consolidated revenue exceeding EUR 750 million are subject to an effective minimum taxation of 15%.

For the purpose of domestic implementation in Liechtenstein, a Gesetz über die Mindestbesteuerung grosser Unternehmensgruppen (GloBE-Gesetz) (The minimum taxation of large groups of companies Act (GloBE Act)) is to be created and the Gesetz über die Landes- und Gemeindesteuern (SteG) (The State and Municipal Taxes Act) is to be amended.

The Draft Act provides for the introduction of a Liechtenstein supplementary tax in the form of an Income Inclusion Rule (IIR), a Qualifying Domestic Minimum Top-Up Tax (QDMTT) as well as an Undertaxed Payments Rule (UTPR). Due to Liechtenstein's membership of the European Economic Area (EEA), analogous to the EU implementation the new regulations will also apply to large domestic groups.

The Draft Act to implement Pillar 2 in Liechtenstein and the accompanying Explanatory Memorandum as sent to the Liechtenstein Parliament can be found here. (In the German language)

 

 

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