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Martina Walt
TLS Partner, PwC Liechtenstein, PwC Switzerland
Background
Liechtenstein on track to introduce the Global Minimum Tax, as communicated in a media release by the Liechtenstein government dated 16 December 2022.
The minimum tax is planned to be introduced by means of the GloBE Act, which shall apply in parallel to the existing Liechtenstein Tax Act and shall be based on, or refer to the OECD GloBE Model Rules. Therefore, multinational companies domiciled in Liechtenstein (including both operating companies and other structures) with a consolidated annual revenue of at least EUR 750 million shall be taxed in Liechtenstein at an effective minimum tax rate of 15%. The taxation shall be carried out by levying a supplementary tax (top-up tax). Multinational companies shall therefore be subject to the minimum taxation desired by the OECD and the G20 states.
The GloBE Act is to be submitted for consultation at the end of March 2023, and the report and motion planned is due to be discussed in the Liechtenstein Parliament in September 2023. The GloBE Act is expected to come into force on 1 January 2024 and is expected to apply to tax years starting in 2024.
Liechtenstein companies of any legal form (AG, GmbH, Stiftung, Anstalt, etc.) that reach the turnover threshold are recommended to analyse the OECD GloBE rules in detail. It is clear that a detailed and data-intensive GloBE tax return will have to be prepared.
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