Minimum taxation (GloBE/Pillar 2)

As of 1 January 2024, Liechtenstein implemented the global minimum taxation of the OECD/G20 Inclusive Framework on BEPS in accordance with the GloBE Model Rules. All domestic constituent entities (legal persons, trusts and partnerships) of a multinational enterprise group or a large domestic group are subject to the minimum taxation for tax years from 2024, provided that their Ultimate Parent Entity has annual revenue of at least EUR 750 million in its Consolidated Financial Statements (including deemed consolidation) in at least two of the four previous fiscal years.

An effective minimum tax level of 15 % is achieved by levying a Liechtenstein top-up tax (“Qualified Domestic Minimum Top-up Tax”; QDMTT) and an IIR top-up tax (“Income Inclusion Rule”). The constituent entities concerned must apply the provisions of the GloBE Act in addition to the Tax Act.

You can find more information in the legal basis as well as in the auxiliary means. You can also obtain up-to-date information from the Newsletter of the Fiscal Authority.