Liechtenstein Issues a Consultation to Amend its Minimum Tax Act

On March 10, 2026, Liechtenstein published a consultation paper on an  amendment to its Minimum Tax Act (GloBE-Gesetz) to update the domestic legal basis for recognising the OECD January 2026 Side-by-Side Package and future safe-harbour developments. It includes  three key provisions: a new version of Art. 28, a new Art. 30a, and an entry-into-force clause. 

Proposed Art. 28: Safe Harbour

Current rule

The current Art. 28 GloBE-Gesetz allows the Government to provide a simplified calculation of top-up taxes only for fiscal years beginning on or before December 31, 2026 and ending before July 1, 2028. The current Global Minimum Tax Regulation (GloBE-Verordnung) implements that rule by reference to the OECD’s December 15, 2022 safe-harbour paper and names only the Transitional CbCR Safe Harbour and the Permanent Safe Harbour rules.

Proposed change

The draft would replace Art. 28 with a broader rule under which the Government determines by ordinance which safe-harbour rules adopted by the OECD apply in Liechtenstein.

This would remove the current sunset provision and delete the statutory reference to a single 2022 OECD document. This would therefore allow Liechtenstein to update its GMT Regulation more quickly to reflect the 2026 OECD package, including the Side-by-Side Safe Harbour, the Simplified ETR Safe Harbour, and the one-year extension of the Transitional CbCR Safe Harbour.

New Art. 30a: Government competence for the GIR MCAA list

Current position

Under the current Global Minimum Tax Regulation, the concept of a partner state already depends on whether Liechtenstein has agreed to exchange GloBE information with that jurisdiction and whether the jurisdiction has been added to the relevant GIR MCAA list. The GloBE-Verordnung already contains an annex listing partner states.

Proposed change

New Art. 30a would expressly state that the Government is competent to add a state or territory to the list under section 8(1)(a)(ii) and (b)(iii) of the GIR MCAA.

This moves the existing operational mechanism onto a clearer statutory footing and supports broader exchange coverage for the GloBE Information Return. That, in turn, should help in-scope groups rely on central filing rather than multiple local filings wherever exchange relationships are in place.

Entry into force

The draft provides that the amending law will enter into force on January 1, 2027, subject to the expiry of the referendum period. That date broadly lines up with the OECD’s timing for the Simplified ETR Safe Harbour, although the OECD package contemplates the Side-by-Side Safe Harbour from fiscal years beginning on or after 1 January 2026.