As of 1 January 2024, Liechtenstein groups and companies (incl. trusts, establishments or foundations), with gross revenue of more than 750 million EUR, are subject to the global minimum tax (GloBE) of 15%, more precisely a Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR) (see PwC Pillar Two Country Tracker).
In this regard, the Liechtenstein tax authority has uploaded a form for the registration of domestic business units of a multinational group of companies or a large domestic group on 9 January 2025. The registration using this “GloBE Registration Form” must be completed unsolicited within six months after the end of the financial year after the group enters the scope of the GloBE Model Rules. A company that falls under GloBE by the end of the financial year on 31 December 2024, must be registered by 30 June 2025.
While the first OECD GloBE Information Return (GIR) is due within 18 months (15 months for following years), the Liechtenstein QDMTT and IIR return is due within 12 months following the financial year end. An extension of the deadline is available upon written request.
The OECD published details and XML schema on 15 January 2025 (OECD GIR Details). Details regarding tax return forms and the system in Liechtenstein have not yet been published.
Further information can be found here.
